ML20215B759
| ML20215B759 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/05/1987 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Congel F Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8706170440 | |
| Download: ML20215B759 (71) | |
Text
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,-( Federal Emergency Management Agency
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Washington, D.C. 20472 JUN - 51987 MD10RANDlM FOR: Frank J. Congel Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulations U.
N clear atory Ca mission FROM:
Richar
' Assistant Associate Director Office of Natural and Technological Hazards t.
SUBJECT:
Interim Finding on Offsite Radiological Emergency Preparedness Plans for the State of 'D3xas and MatagordaCountySite-bpecifictotheSouthTexas Project Electric Generating Station Attached is documentation prepared by the Federal Emergency Management Agency'(FEMA) staff in Region VI that will form the basis of an interim finding on offsite radiological emergency preparedness planning around the South Texas Project Electric Generating Station. The offsite juris-dictions addressed in this finding are the State of Texas and Matagorda County.
This interim finding consists of a review of the State of Texas and IMatagorda County Plans based on Section II-(A through P), Planning Stan-dards aM Evaluation Criteria, NURDG-0654/FD4A REP-1, Rev.1. For both the State and County Plans, all NUREG-0654/ FEMA REP-1, Rev. 1, elements have been reviewed by the Regional Assistance Ccmmittee and FEMA and are considered adequate. In addition, medical services capabilities for the State.of Texas and Matagorda County have been reviewed pursuant to Guidance Memorandum MS-1, Medical Services, and with the exception of one item, all requirements have been satisfied. The item not addressed involves the annotation of the hospital list to indicato ambulatory /non-ambulatory capacities.
It is the position of the State of Texas that since the ambulatory /non-ambulatory status of patients is assessed on a daily basis by hospital officials, adding this information to the hospital list would not serve any useful purpose.
Based on this offsite plan review, there is reasonable assurance that
' p" the offsite radiological errergency preparedness plans for the South l
Texas Project Electric Generating Station are adequate to protect the m k.
health and safety of the public. The initial exercise for South Texas lf a.
L L
Project Electric Generating Station was conducted on April 8,1987.
L3 When this exercise report becomes available, it will be forwarded to
~
w your office.
-pr If you should have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2860,
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Attachments
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May.29, 1987 FIRST INTERIM FINDING ON SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION (STPEGS) 0FFSITE RADIOLOGICAL EMERGENCY PREPAREDNESS
.1 c
TEXAS STATE PLAN l
CONSOLIDATED FEMA /RAC p
REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE-AND-0F TEXAS TO. CORRECT q.
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES A,1 0, Preamble : page i Identifies Federal, State and local organi-JADEQUATE' Part One, V.A.'(pages zations including the. utility (STPEGS) that -
6 & 7).
have responsibilities under the plan. Tab 1 Part One, Attachment 1 Chapter 2 is specific to STPEGS.
l (page 1)
'A.1.b.
Part One, IV.A. through State Plan adequately addresses each or-ADEQUATE C. (pages 4 &-5) ganization and suborganization having an
- Part One, V.A. & B operational role including concept of op-l (pages 5 &'7) erations and its relationship to the total Part-Two, III. & IV effort.
(pages:3-7)
Part:Three IV.B (pages 4 & 5)-
's
'i Appendix 7 - Sect. V. A.4.,
p.3
" - Sect. V.A.5.,
p.3
" - Sect. V.B.6.,
p.4
" - Sect. VII.A, p.7 b ' A. l.C..
Basic Plan, Part One, Interrelationships adequately illus-
};7 ADEQUATE-~
trated in block diagram and primary /
Hg Appendix 7 - Att. 2, support matrix.
- p. 30
. Tab 1 Introduction.,
- p. 11 J/L i
a' y.
5 2.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND-NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCE PREVIOUS INADEQUACIES A.1.d Part One, VI.A.l. &
Director, Division of Emergency Management ADEQUATE
- 2. (pg. 7) serves as Chairman of Emergency Management Appendix 7 - Sect.
Council and has overall control of the VII.A.2, p.8 emergency response.
For radiological re-sponse, he would be advised by the Commis-sioner of Health, the Chief of Bureau of Rad. Control, and the Chief of Field Op-
)
erations.
A.l.e Part One, V.B.2 Authority and responsibility maintained ADEQUATE (pg.7) for 24-hour emergency response capability
{
Appendix 7 - Sect. VI.C, and manning of communications links. A q
p.6 recall list is provided in Attachment 5, Tab 1, Chap. 2 - Sect.
App. 7, p.32 listing both home and. office i
V.D.,
- p. 7 phone contacts.
Annex L VII.A.4., p. 11 A.2.s Com. & Control: Part One, Functions and responsibilities for major ADEQUATE V.A. & B. (pgs. 6 & 7) &
elements and lead individual by title are Part One, VI.A. (pg. 6) covered in Plans.
State (DEM) has author-
)
Alerting & Notification:
ity to request Federal assistance. Appen-j Part One, V.B.2 (p. 7) dix 7, page 30 illustrates the primary /
Part One, Att. 5 (p. 19) support chart.
Part One, Att. 5 (p. 28)
Part Two, III.A.2.b We suggest that additional material be (p. 4) added detailing the control of air and Communications: Part One, rail traffic, over and through the EPZ, VI.B.1. (p. 8) during an emergency.
4 Public Information: Part One, Att. 5 (p. 28)
Even though A.2.a. was evaluated as ade-Annex AA 5.C.3. (p. AA3) quate, the following action was taken by Accident Assessment:
See the State of Texas for suggested improve-Annex L & Append. 7 ment to the Plan.
Public Health & Sanita-tion:
See Annex L Plan text will be expanded to include Social Services:
See water traffic, since the Intracoastal Annexes P, S & CC Waterway runs through the STPEGS 10-Fire & Rescue:
See Local mile EPZ.
Plans Traffic Control:
See The state plan will be revised as follows:
Annex R Trans portation:
See Local I.
An addition to Annex AA (The Divi-Plans sion of Emergency Management's annex Protective Response:
Part to the basic state plan) the Divi-Two, II.B.2. (p. 3) sion's Duty Officer manual will
3-1 4
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCE PREVIOUS INADEQUAGIES A.2.s (cont'd)
Radiological Exposure Con-ins truct the Duty officer to con-trol: See App. 7 to Annex L tact FAA upon receipt of notifica-Part One:
I. (p. 2) (See tion that a Site Area Emergency or Part 4 for text) a General Emergency has been de-Preamble (pages ii-v) clared at either STPEGS or CPSES.
Appendix 7 - Sect. VII.,
The Duty Officer will request the pp. 7-22 FAA to restrict air travel over Tab 1 Chap. 2, Sect. VI.C, the 10-mile EPZ of the affected pp. 8-18 power plant.
Appendix 7, Attach. 2,
- p. 30 II.
If the event involves STPEGS, a similar addition to the above docu-ment will instruct the Duty Offi-cer to contact the US Coast Guard and request restriction of water traffic on the Intercoastal Water-way and the Colorado River if they are within the affected portion of the STPEGS 10-mile EPZ.
III. An addition to Annex V (The Rail-road Commission of Texas) will in-j struct that agency to contact af-fected railroad companies upon re-ceipt of notification that a Site Area Emergency or a General Emer-
{
gency has beer / clared at either 3
plant.
A.2.b.
Appendix 7 - Sect.
I.A.,
State Emergency Management Plan, Annex j
ADEQUATE
- p. 1 L, Appendix 7 lists all legal basis Appendix 7 - Sect.
I.B.,
authorities.
- p. 1 o
e' g.
8 r.s t
y
- 4. '
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
' NUREG CRITERION ACTION TAKEN BY STATE AND' 0F TEXAS TO CORRECT EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES A.3
. Tab 1 Introduction, Sect.
State plan has signature page for state ADEQUATE VII., pp. 4-9 ager;cies. American Red Cross functional
- (Previous' )
. Tab 1 Introduction, statement included.
(Annex L) Tab 1 to
- (Inadeq ua te), p.12 Appendix 7 has responsibilities of other
-(Rasolved.)
Tab 1 Introduction, state departments and utility listed., p.16 Written agreements with U.T. Austin and (See basic plan for Texas A&M. Authority to implement Fed-agency signatures.)
eral Radiological Response plans'is'es-
. Procedure 5, p. 21 tablished in plans. Other Federal As-sistance will be requested and provided-according to authority and ' procedures established in the Annex assigned to the~
State agency who works with the Federal agency on a day-to-day basis.
Hospitals listed as support facilities do not have letters of agreement as re-quired in Guidance Memorandum MS-1.
Action taken by the State of Texas Hospitals listed in Procedure 5 in our plan are there because they have at least some degree of capability in the desired areas.
It is the responsibility of the attending physician or the refer-ring hospital to contact the receiving f acility in order to ensure that the patient's specific needs can.be met.
l We will annotate the list of facilities to show whether they are private, State, military, etc.
1 While we do not feel that they will add anything to State response capabilities, letters of agreement will be solicited j
from the hospitals currently listed in to Procedure 5.
Letters of agreement from appropriate additional facilities will be incorporated in the State Plan when FEMA identifies a measurable standard which they consider to be acceptable.
i s,
,e 5.
4 i
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES A.4 See Annexes to the Capability of Health Department contained ADEQUATE Texas Emergency in Annex L.
State EOC (DPS/DEM) capability Management Plan for 24-hour per day operations noted. App.
Appendix 7, Sect.
7 under Logistics Support, Emergency Recall VII.B,11., p. 15 Procedures and Supervisory responsibility Appendix 7, Sect.
assignments by individual. Cross refer-VII.B.15., P. 20 ence to App. 7, p.19 has been corrected.
Appendix 7, Att. 7, BRC response team personnel will be acti-
- p. 40 vated and will maintain 24 hr. operational Tab 1 Chap. 2, Sect.
capability until event is resolved.
V.D.,
- p. 7 C.l.a.
Part Three, III.B.4.
Plan provides that the Chief of the BRC (p. 3) is responsible for requesting, through ADEQUATE Appendix 7 - Sect.
7.A.2.,
the Emergency Management Council (Chaired
- p. 8 by the Director of DEM) assistance which Appendix 7 - Sect. IX.,
may be required. Plan further provides
- p. 24 that the BRC may submit requests for fed-Tab 1 Introcuction, eral radiological monitoring assistance Sect. VII.C.6., p. 6 directly to DOE, or, for other types of assistance, through the Division of Emer-ency Management to FEMA. Under the pro-vision of the Southern Mutual Radiation Assistance Plan (SMRAP), requests for support will be made by the of fice of
{
the Governor.
j l
C.I.b.
Tab 1, Introduction, Federal resources expected to assist ADEQUATE Sect. VI.B.4., p. 4 State and local governments are listed Tab 1, Introduction, in the state cross reference.
Plan pro-Sect. VI.B.S., p. 4 vides that request for f aderal assistance Tab 1, Introduction, is not anticipated but, if necessary, Sect. VI.B.6., p. 4 will be requested in accordance with the Tab 1, Introduction, FRERP. Matagorda County plan contains At tachment 1 an adequate discussion of those resources S.M.R.A.P.
that may be available to support the fed-F.R.E.R.P.
eral respunse.
i w
6.
g.
CON 3OLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
'C.1.C Tab 1 Introduction, In addition to resources listed in stated ADEQUATE Sect. VI.B.6., p. 4 references a site-specific plan will be Tab 1, Chap. 2, Sect.
developed by FEMA which will cover all III.D. p. 5 required items. The site specific plan Att. 1 to Tab 1, Intro-will be a part of the F.R.E.R.P. which duction, p. 9. Tab 1 is referenced in the Texas plans. The Introduction VII, Chg.
Matagorda County plan also lists certain 2, p. 28 S.M.R.A.P.
support resources for federal response.
C.2.a..
Tab 1 Chap. 2, Sect.
State plans provide for dispatching to i
ADEQUATE III.B.l., p. 4 the near-site utility EOC: 1) A License Tab 1 Chap. 2, Sect.
Liaison Team; 2) Field Monitoring Team VI.C.l., p. 9 Leader; 3) Accident Assessment Team, and Tab 1 Chap. 2, Sect.
- 4) An Administrative Support person.
Ad-VI.C.2., p. 9 ditionally, while not stated in the plan, Tab 1 Chap. 2, Sect.
the Chief of Field Operations will be VI.C.6., p. 11 located in the STPECS E0C.
Tab 1 Chap. 2, Sect.
VI.C.12, p. 17 i
.Also Appendix 7 to Annex L i
l C.3 Tab 1 Chapter 2, Sect.
State Plan provides for using the Depart-
)
ADEQUATE VI.C.4., p. 9 ment of Health's mobile laboratory, the j
Tab 1 Chapter 2, Sect.
Dept's main lab in Austin or the labora-4 VI.C.S., p. 10 tories of University of Texas and Texas l
Tab 1 Introduction A&M. Adequately addresses the general Attach. 2, p. 13 radiological capabilities of these labs.
Tab 1 Introduction Attach. 3, p. 16 C.4 Tab 1 Introduction State Plan adequately describes facili-ADEQUATE Sect. VI.B.4., p. 4 ties, organizations and individuals that (Also see the Southern can be relied upon to provide assistance.
Mutual Radiation Asst.
State will utilize, if necessary, the Plan which has been Southern Mutual Radiation Assistance Plan.
previously submitted SMRAP listed as first option for outside for RAC review).
assistance.
Laboratory facilities at U.T.
Austin and Texas A&M have agreed to pro-vide assistance. Letters of agreement and capabilities included.
1
7.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES D.3 Tab 1 Chapter 2, Sect.
State classification scheme is consis-ADEQUATE IV., p. 6 tent with Federal Guidance and that of Appendix 7 to Annex L the utility.
D.4 Tab 1 Chapter 2, Sect.
State resp use levels are appropriate ADEQUATE V.,
- p. 6 and consistent with the utilities and Annex R and Appendix 7 the NUREG-0654 classification levels, to Annex L E.1 Tab 1 Introduction Sect.
State Plan provides that STPEGS will no-ADEQUATE VII.A.l., p. 4 tify Texas Dept. of Public Safety (Pierce, (Previous )
Tab 1 Introduction Sect.
District) which will in turn notify the (Inedequat e)
VII.A.2., p. 4 Division of Emergency Management which (Risolved
)
Tab 1 Introduction Sect.
will in turn notify other state agencies.
VII.A.3., p. 4 But, where are bases for notification?
Tab 1 Introduction Sect.
When, for example, will notification be i
VII.A.4., p.5 passed on to the Bureau of Radiation Con-l Tab 1 Introduction Sect.
trol (BRC)? At what level? Notification VII.B.1., p. 5 is implicit in plan, but cannot locate Tab 1 Introduction Sect.
section that discusses details of system.
VII.C.1., p. 6 Annex L designates disaster response pro-Tab 1 Chapter 2, Sect.
gram of Dept. of Health as point of con-IV., p. 6 tact. How does BRC receive prompt noti-Tab 1 Chapter 1, Introduc-fication?
tion Sect. VII.B.2.b.,
- p. 8 of Annex L Action taken by State of Texas Both STPEGS and CPSES have committed to direct telephone notification of the Bureau of Radiation Control upon initial declaration of any emergency classifica-tion, and upon any change or termination of such declaration. Each telephone call will be followed by a telecopied message containing pertinent data. This direct notification is to follow immediately after notification of DPS Waco or Pierce and the affected local government (s).
t J
(, ;
5.
8.
CONSOLIDATED FEMA /RAC REVIEW COHMENTS AND
.NUREG CRITERION ACTION TAKEN BY STATE uAND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES i
E.1.-(cont'd)
A new item will be added on page 5 of the Bureau of Radiation Control's Tab 1, Introduction (General FNF Response),
concerning'the telephone and telecopier.
notification.
This commitment to provide direct noti-fication is also incorporated in the emergency procedures of each operating utility, and in the SOP's of ' the Temas Department of Public Safety Communica-tions Service for their Pierce and-Waco radio stations.
E. ' 2 Appendix 7-Sect. VI.C.,
State plans adequately establish proced-ADEQUATE
- p. 6 ures for alerting, notifying and mobiliz-Appendix 7-Sect. VII.B.1, ing emergency response personnel. This
- p. 9 was demonstrated satisfactorily during Appendix 7-Attachment 5, the CPSES exercises of December 14, 1983
- p. 33 and November 14, 1984.
{
Tab 1 Chapter 2, Sect.
j V.,
- p. 6 Procedure 10-Sect. VIII.A, i
P. 3 Procedure 10-Sect. VIII. B.
p+ 4 4
Part one, V.B.2. (p. 7)
Part Two, V. A. (p. 7)
Annex AA, V.B.3 (p. AA2)
.E.5 (The Bureau of Radiation A general summary of state responsibili-
' ADEQUATE Control will provide rec-ties for message dissemination is covered ommendations to local gov-in State plan, but specifics for notify-ernment, but actual dis-ing the public are reserved to the local semination of information plans, and Dept. of Public Safety Pro-to the public, and the cedures. Both State and Local plans are wording of emergency pub-in agreement.
lic information messages, is a local government re-sponsibility.)
Annex R and Appendix 7 to Annex L j
9.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS
]
AND j
NUREG CRITERION ACTION TAKEN BY STATE l
AND OF TEXAS TO CORRECT l
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES E.6 Same comments as for As with E.5, State plan is limited to a
]
ADEQUATE NUREG 0654 Criterion general statement regarding providing E.5.
It is a local prompt. instructions to populace.
Specific responsibility and is administrative and physical means are de-to be covered in local fined in local plans and Annex applicable plans.
to the agency involved in notification Also, refer to Annex R and instructions to the public.
for Warning to Local Government E.7.
See Local Government Bureau of Radiation Control will advise N/A Plans local government regarding protective measures but the content of the me,ssages and its dissemination is a local respon-sibility.
F.1.c.
Part One, V.B.2.,
(p. 7)
State plan directs agency heads to de-ADEQUATE Part One, V.B.l.,
(p. 8) velop appropriate notification proced-Pa rt Two, II. B., (p. 5) ures. Reference DPS (Annex R) and DEM Annex AA, V.B. (p. AA2)
(Annex AA) as primary responsible agen-See Annex R cies for 24-hour per day communications Appendix 7 Attachment 6, links.
State has assured that.appro-
- p. 39 priate agency annexes relating to 24-hour per day communictions/ notification comply with the NUREG-0654 criteria.
State Plan provides that the State EOC in Austin employs the communications network of the Dept. of Public Safety.
Primary notification from STPEGS to State is by dedicated telephone to DPS's disaster district in Pierce, TX which in turn notifies Austin State of fice 7
(E00) and State EOC in turn notifies I
BRC.
F.1.b.
Annex R There are no contiguous states within ADEQUATE Tab 1 Chapter 2 the EPZ. Local government communica-Sect. VI.C.6., p. 11 tion is directed by DPS (Annex R).
l Tab 1 Chapter 2 Local plans provide for telephone com-Sect. VI.C.13, p. 17 munications with adjacent counties.
l
s 10.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES F.1.c.
Annex R & Annex AA DPS/DEM (Annex R and AA respectively) Tab ADEQUATE Tab 1 Introduction Sect.
1 indicates proper channels are DEM/ FEMA II.C.3. of Attach. 4, Region VI via telephone, NAWAS and NACOM.
- p. 22 Tab 1 Chapter 2, Sect.
VI.C.6., p. 11 F.1.d Annex R Rad Monitoring team communications covered ADEQUATE Tab 1 Chap. 2, Sect.
in State plan by assigning responsibility VI.C.2., p. 9 to Health Department radio augmented by Tab 1 Chap. 2, Sect, DPS radio. A radiological incident l
VI.C.6, p. 11 would not require communications other Procedure 10, Sect.
than those used at State level for any VIII.E, p. 7 other type communications needs. Local Procedure 10, Sect.
communication provisions addressed in XII.A., p. 39 Local plan. Plan provides for communi-cations between the listed organizations.
F.1.e.
Part One: V.B.2. (p. 7)
State plan assigns responsibility to ADEQUATE Part Two: V.A. (p. 7) agency heads.
Indicates priority of Appendix 7 Sect.
order call to be established within VI.C.2.b., p. 7 emergency management council agencies.
Procedure 10 Sect.
Health Department responsibility for VIII. A., p. 3 alert and activation of emergency per-sonnel is responsibility of the Direc-tor of Disaster Response Program.
(Warning and emergency communications is responsibility of DPS. Agency noti-fication is responsibility of DEM).
F.2 See Local Government Fixed and mobile medical support fa-N/A Plans cilities communications link is respon-sibility of the appropriate local gov-ernment.
=
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- .?,.-
11.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT.
EVALUATION ~
CROSS REFERENCES PREVIOUS INADEQUACIES
.F.3 Part 1, VII.G. (p. 9)
Periodic testing of State Communications ADEQUATE See Appendix-7 to Annex system is established on an annual basis L, Annex R & Local Plans or by monthly drills.
Tab 1 Introduction Sec.
II.B.1. of Attach. 4,
- p. 21 Tab 1 ' Introduction Sec.
II.C. of Attach. 4, p. 22 G.1 Annex AA, APP. II. &
The State does not have a role, accord-g ADEQUATE Local Plans ing to State comments, in annual or periodic dissemination of information i
to the public. All responsibility is held by local government agencies and the utility.
j i
G.2 See Local Government Public Information Program is a local N/A '
Plans government responsibility.
1 G.3.a.
Part Two, III.B.4.
Annex L, Tab 1, Chapter 2 provides that ADEQUATE (p. 5) the joint Media Information Center is Annex AA, APP. II located in the Holiday Inn in Bay City.
Annex R Appendix 7 Sect. VII.B.
13., p. 18 Tab 1 Chapter 2 Sect.
III.B.2., p. 4 Tab 1 Chapter 2 Sect.
VI.C.8., p. 14 G.4.a.
Part One, Attachment 3 DEM has primary responsibility for dis-ADEQUATE (p. 1) semination of emergency public informa-Also see Annexes L & R tion. Single point of contact for Emer-j Annex AA, APP. II gency Public Information (EPI) release Appendix 7 Sect. VII.B.1, and for persons seeking information is
- p. 9 DEM. Bureau of Radiation Control will Appendix 7-Sect. VII.B.13, also have a public information coordina-
- p. 18 tion team which will consist of one or Tab 1 Chapter 2 Sect.
two BRC spokespersons per shif t and they VI.C.8., p. 14 will be in contact with BRC personnel in i
1 i
i e'
s 12.
i i
CONSOLIDATED Fl:MA/RAC REVIEW COMMENTS i
AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES G.4.b.
Annex AA, APP. II Bureau of Radiation Control Public In-ADEQUATE See Annexes R and formation coordinator will arrange for Appendix 7 to Annex L timely exchange of information with ap-Appendix 7 - Sect. VII.
propriate licensee and local government
]
B.13.a., p. 18 public information personnel.
G.4.c.
Annex AA, V.C.3.
Appendix 7 provides for coordinated ADEQUATE (p. AA3) release of information to forestall or See Annexes R and correct rumors.
Appendix 7 to Annex L Appendix 7 - Section VII.B.13.c., p. 18 G.5 See Local Government Not a State responsibility.
- However, N/A Plans
' the Bureau of Radiation Control will assist in development of public infor-mation materials to be released for annual exercises.
H.3 Part Two, Section State Plan provides for conducting ADEQUATE III.A.3.a. (p. 6) emergency operations from the State Tab 1 Chapter 2 EOC in the Dept. of Public Safety Sect. III., pp. 3-5 Headquarters in Austin, TX and the Disaster District EOC in Pierce, TX.
H.4 Part Two, Sect. III.A.
Timely activation and staffing of ADEQUATE 3.c. (p. 4)
State EOC will be directed by State Part Two, Sect. III.B.
Coordinator of DEM. The District EOC
- 1. 6 2. (p. 5) will be activated and manned by the Annex AA, V.B. (p. AA-2)
Disaster District Committee Chairman.
The Emergency Management Council will BRC provisions for maintain operational capability at the timely staf f of facili-EOC.
ties are described in:
Appendix 7, Sect. VI.C.,
- p. 6 Appendix 7, Attach. 5,
- p. 33 Tab 1 Chapter 2 Sect. V,
- p. 6 a
r; bf
, g1 u;
t-
"13.
l J
CONSOLIDATED FEMA /RAC REVIEW COMMENTS j
AND J
NUREG CRITERION.
ACTION TAKEN BY STATE 4AND OF-TEXAS TO CORRECT EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES
.j 1
1 H.7
'See' Appendix 7 to BRC will bring equipment in response to ADEQUATE Annex L incident. Equipment to be brought by Tab 1 Chapter 2 field monitoring teams listed in Pro-Sect. VI.C.3., p. 9 cedure 10, Attachment-1, page.43, also Procedure 10 Att. 1, an extensive list.cf additional equip-
- p. 43 ment provided through the Southern Southern Mutual Radia-Mutual Radiation Assistance Plan.'
tion Assistance Plan, 0-pp..34 & 35
'H.
10 Appendix 7 to Annex L, Annex. 7 provides that equipment 'is in
- ADEQUATE Section VII.B.14., p. 19 daily use and that calibration is per-i formed semi-annually, more -frequenely than recommended by manufacturer.
i Therefore, instrument inspection, maintenance and calibration is ade-
-)
quately addressed:in Plans..
H,11 Procedure 2-Sect. IV.,
All equipment and supplies. required are ADEQUATE
- p. 2-1 listed. Emergency equipment is identi-Procedure 5-Sect. IV.,
fied in individual procedures. Team l
- p. 1 members are responsible for ensuring '
l Procedure 7-Sect. IV.,
that appropriate equipment is brought.
- p. 1 When issued, Procedure' 7 will specify, Procedure 8-Sect. V, p. 3-as a minimum, the following personnel Procedure 10-Attachment 1,-
dosimetry for each ' emergency response l
- p. 43 team member operating within the 10.
mile EPZ or at support' facilities within Matagorda County.
1 Harshaw/Filtrol TLD-100 dosimeter; 1 Response Team ID card with two in-corporated Teledyne Isotopes TLD l
(CaSO :Dy) chips; 4
1 CVD-730 0-20 R direct reading pocket i
dosimeter; and 1 CDV-138 0-200 mR direct reading pocket dosimeter.
I
{
1.
14.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT
-EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
~
-H,11-(cont'd)
Adequate supplies of 'all these devices are already on hand and team training concerning their use has been conducted, as has been demonstrated in previous ex-r ercises for the Comanche Peak Stream Electric Station.
Other personnel do-simetry devices available to individual team members may be worn in addition to.
j the above specified items.
H.12 Appendix 7 to Annex L ADEQUATE Tab 1' Chapter 2, BRC sample preparation and coordination Se ct. VI.C.4., p. 9 team will collect and route all sapples Tab 1 Chapter 2, collected by field n9nitoring' teams or Sect. VI.C.5., p. 10 others. to the mobile laboratory which Tab 1 Chapter 2, will be parked near the STPEGS E0C or Sect. VI.C.6., p. 11 some other designated location as re-Tab 1 Chapter 2, quired by the accident situation. All, p. 22 field monitoring data wil be transmitted to the field monitating team leader in the STPEGS EOC. All results of analyses will be collected by this team and dis-seminated to the accident assessment team in STPEGS EOC or entered into the J
mobile laboratory's computer.
l I.7 Annex R and Appendix 7 Description of field monitoring teams ADEQUATE to Annex L and their capabilities are adequately Tab 1 Chapter 2, Sect.
addressed. Equipment listed in Pro-VI.B.1., p. 8 cedure 10, Attachment 1.
Tab 1 Chapter 2, Sect.
VI.C.3., p. 9 Procedure 10, Attach.1,
- p. 43 1.8 Annex R and Append. 7 The procedure to be used by the Bureau
' ADEQUATE To Annex L of Radiation Control to make rapid as-j Activation:
sessments of the actual or potential j
I J
1 15.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES I.8 (cont'd)
Appendix 7, Sect.
magnitude and locations of any radio-VI.C., p. 6 logical hazards through liquid or gaseous Attach. 5, p. 33 release pathways are adequately explained Tab 1 Chapter 2 in the plan.
Section V.,
- p. 6 i
Notification Means:
Appendix 7, Sect. VI.C,
- p. 6 Appendix 7, Attach. 5,
- p. 33 Field Team Composition:
Appendix 7, Attach. 5,
- p. 33 Tab 1 Chapter 2, Sect.
VI.A., p. 7 Tab 1, Chapter 2, Sect.
VI.B., p. 8 Southern Mutual Radiation Assistance Plan, p. 7.33 Transportation: Transportation will be by private vehicles except:
Tab 1 Chapter 2,Section VI.C.2., p. 9 Communications:
Tab 1, Chapter 2, Sect. VI.C.2., p. 9 VI.C.3., p. 9 VI.C.4., p. 9 VI.C.5., p. 10 VI.C.6., p. 11 VI.C.7., p. 12 VI.C.8., p. 14 VI.C.9., p. 15 VI.C.10., p. 16
p.
k 16.
CONSOLIDATED FEMA /RAC REVIEW C0HMENTS p
AND' NUREG CRITERION,
ACTION TAKEN BY STATE
~AND OF TEXAS TO CORRECT j
i, ' EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES I.8'(cont'd)_
VI.C.11., p. l'7 VI.C.12., p. 17 VI.C.13., p. 17 Monitoring Equipment:
Tab 1' Chapter 2, Sect.
VI.C.5., p. 10 Procedure 10, Attach. 1,
- p. 43 Southern Mutual Radiation Assistance Plan, p. 7.35 Assessment Methods:
Tab 1 Chapter' 2, ' Sect.
VI.C.6., p. 11-Deployment Times:
i Tab 1 Chapter 2, Sect.
V.D.,
- p. 7 I.9 Appendix 7 to Annex L Bureau of Radiation Control provides'
-ADEQUATE Tab 1 Chapter 2, Sect.
a system capable of meeting detection VI.C.5., p. 10 and measurement of radioiodine concen-Procedure 10, Sect.
tration levels required by this element.
XI.A.3,~p. 16 BRC claims at least 10-10 u Ci/cc sensi-Procedure 10, Sect.
tivity, which is 1000 times better than XI.A.5, p. 19 NUREG-0654 requires. Procedure 10 pro-vides the detailed instuctions.
I.10 Appendix 7 to Annex L Procedure #1 incorporates EPA recommended
' ADEQUATE Tab 1 Chapter 2, Sect.
levels and those of other Federal agencies.
VI.C.6., p. 11 The means for relating contamination levels Procedure 1, Sect. VII.A.
and air and water activity levels to dose 1.b., pp. 1-3 rates as required by this element are to Procedure 1, Sect. VII.C.,
be accomplished through trained team mem-pp. 1-20 bers' knowledge and use of the EPA Guide Procedure 1, Attach. 3, 520/1-75-001 Rev. 6-80.
pp. 1-27 J
Procedure 1, Attach. 4, pp. 1-29 1
.,e' 17.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS l
AND-l-
NUREG CRITERION ACTION TAKEN BY' STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES 1
1
'I.11 Part One, Attach. 5, The State has established a policy for ADEQUATE (p. 13) locating and tracking the airborne radio-
'Also see Annex L;
-active plume. Twelve teams are author -
Appendices.3 & 7 ized and may be activated simultaneously Appendix 7, Sect.
if necessary or split into shif ts.. They VII.B.S., p. 11 possess required capabilities for meeting Tab 1 Chapter 2, Sect.
this requirement.
State does not think VI.C.3., p. 9 they will need federal' assistance regard-Procedure 10, Sect. IX, ing meeting this element.
- p. 8 l
J.2' See Local Government Refer to local plan since it is a local-
)
N/A Plans res ponsibility.
J.9 See Annexes C and L, and Responsibility for. implementing protec-l l.
ADEQUATE
' Local Plans tive actions for the people rests with-
]
l
-Also see Appendices 2, 7, county government. For all other pro-and 9 to Annex L tective actions, plan assigns responsi-Y Appendix 7, Sect. VII.A.
bility to various bureaus of the State
- p. 7.
Dep t. of Health. Procedure 1 relies on Appendix 7, Sect. IX.,
EPA and FDA guidance.
- p. 24 Tab 1 Introduction, Sect.
VII.D., p. 6 Capabilities for Dept. of Agriculture j
Tab 1 Introduction, Sect. and Dept. of Health are established j
VII.R., p. 7 in their respective annexes.
j Tab 1 Introduction, Sect.
j l
VII.F., p. 7 Tab 1 Introduction, Sect.
.VII.G., p. 8 i
Tab 1 Introduction, Sect.
j VII.H., p. 8 1
Tab 1 Introduction, Sect.
j VII.I., p. 9 Tab 1 Chapter 2, Sect.
)
VI.7., p. 12
)
1 ti?
"I. -L' J
'/
K 4
18.-
CONSOLIDATED FEMA /RAC-REVIEW COMMENTS AND NUREG CRITERION -
ACTION TAKEN BY STATE AND OF. TEXAS TO CORRECT
' ' EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
.J.10.a l See Appendix 7 to' Annex L State Plan includes all required maps.
ADEQUATE-
.& Local Plans Evacuation Routes map:
- Tab 1 Chapter 2, Attach.
-l E
14, p. 41.
Evacuation Areas map:
Tab.1 Chapter 2, Attach.
13, p. 39 Preselected Sampling & Moni-toring Points map Tab 1 Chapter :2, Attach.13, p.129.
Relocation Center maps:
Tab 1 Chapter 2, Attach.
10,'p. 33 Tab 1 Chapter 2, Attach.
11,.p. 35 Shelter' Areas map:
Tab 1 Chapter 2, Attach.
13, p. 39
- Larger copies of all these maps will be available at each of the emergency operating centers and the Media Inforention Center. Larger copies of selected maps will also be available at the Reception Center (s) and at the hospital (s).
)
.i C-i
. e<
19, CONSOLIDATED FEMA /RAC REVIEW COMMENTS j
AND 1
NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES i
I' J.10.b Tab 1 Chapter 2, State Plan includes maps with population -
ADEQUATE Attach. 12, p. 37 distribution by sectors, but not one by (Provious )
Also see Local evacuation areas.
j l
. (Inadeq uat e)
Government Plans 1
l (Resolved)
Action taken by the State of Texas A map showing population distribution by evacuation areas has been developed i
I and will be included in the next update of Tab 1, Chapter 2, STPEGS.
J.10.c.
See Annex R and Local This is a local governcient responsibility N/A Government Plans and the local plans do address the.means for notifying all segments of transient and resident population.
J.10.d See Appendix 7 to Levels of protection to mobility impaired ADEQUATE Annex L persons are established and outlined in Procedure 1, Section plan. Type of protection will be deter-
.VII.4.a.(3), pp. 1-9 mined by the projected. dose to which they l
will be exposed.
J.10.e See Appendix 7 to Annex L State Plan lacks this information current-
!. ADEQUATE A supply of KI adequate ly but commits to having KI available (Provious )
for emergency workers and prior to fuel load.
Procedure 9 concern-(Intdaquate) mobility-impaired persons ing Radio-protective Drugs to be issued at (R2 solved )
will be purchased by the a later date. This almost is considered Bureau prior to STPEGS inadequate until proof of KI availability, fuel load.
Use of this including quantities, storage and means of supply will be addressed distribution are provided.
j in Procedure 9 - Radio-j protective Drugs, which Action taken by State of Texas j
will be issued prior to
]
fuel load.
The Bureau of Radiation Control now has j
200 bottles of 130 mg KI tablets at 14 j
tablets per bottle. Fifty bottles, j
along with manufacturer's leaflets con-taining instructions for use, will be provided to Matagorda County for dis-l tribution to local government emergency l
l l
l
a 20.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT f
l EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES l
J.10.e (cont'd) workers and mobility-impaired residents of the EPZ.
The remaining supply, along with manufacturer's instructions, will be made available to State emergency l
workers for use on a voluntary basis.
Details of storage, distribution and 4
sug8ested use will be documented in
)
Procedure 9, Radio protective Drugs.
l This procedure will be issued to all emergency plan holders as a part of the l
next plan update. The gist of those l
details are as follows:
a.
One bottle of K1 tables will be issued to each Bureau of Radiation Control Field Monitoring Team member.
b.
The remaining supply of KI will be stored in Austin.
i c.
Supplies will be distributed to l
other response team members at the
)
staging area prior to deployment.
q d.
If dose projections indicate emer-l gency PAGs for thyroid might be ex-l ceeded, use of KI will be recommen-i ed for personnel operating in the l
affected portion of the plume ex-posure EPZ. As the designee of the l
Commissioner of Health, the Chief of Field Operations will issue that i
recomme ndation.
e.
Use of KI will be a matter of indi-vidual choice.
jg A
21.
CONSOLIDATED FEMA /RAC REVIEW C0KHENTS AND NUREG CRITERION -
ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT
-EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
- J.10. f. -
See Appendix to Annex L The State Health Dept. has decided not ADEQUATE KI for the general public:
to issue radio protective drugs to the The State Health Dept.
general population.
Procedure 1 estab-has decided not to ad-lishes exposure projections at which minister radioprotective use of KI should be considered for q
drugs to the general pub-Emergency Workers. Add Procedure 1
]
lic'during an emergency.
to Cross Reference Section VII, Para..
j A.4.a., pp. 8-10.
1 I
J.10.g.
See Local Government Means of relocation is under the direc-N/A Plans tion of the local governments.
J.10.h.
Tab 1 Chapter 2, Sect.
State. Plan describes support to the ADEQUATE II.A.3., p. 2 reception centers established in.the
.(Previous )
Tab 1 Chapter 2, Sect.
local plan. These centers are not 5 (Inadequa te)
VI. C. 9., p. 15 or more miles outside the 10 mile (Rarolved )
Tab 1 Chapter 2, plume EPZ as required by this element.
Attach. 10, p. 33
]
Tab 1 Chapter 2, This entire issue was thoroughly dis-Attach. 11, p. 35 cussed and reviewed with FEMA National.
An exemption was granted by FEMA since the next closest reception center site
.{
would be 23 miles outside the 10-mile j
plume EPE. Thus, an adequate evalua-
]
tion was determined.
i t
J.10.1.
See Local Government Projected traffic capacities is a local N/A Plans res ponsibility.
I J.10.j.
See Local Government State BRC has role in determining areas ADBQUATE Plans and Annex R that should be controlled. Also assign Tab 1 Chapter 2, Sect.
contamination control teams to access VI.C.7., p. 12 ccatrol points. Enforcement of access control is responsibility of local and State law enforcement of ficals.
l
,,5; 1...
22.
I J
J CONSOLIDATED FEMA /RAC
)
REVIEW COMMENTS' AND i
NUREG CRITERION ACTION TAKEN BY STATE
-l ANDS OF TEXAS TO CORRECT
.l EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES J.10.k.
See Local Government Identification of and means for dealing N/A' Plans with potential impediments.is a local government responsibility.
J,10.1.
See Local Government Evacuation time estimates in a local N/A Plans government responsibility and should be addressed in local plans.
J.10.m.
See Appendix 7 to Annex L State does not plan to factor in pro-ADEQUATE Procedure 1, Sect. VII.A.
tection af forded by local _ housing and 4., pp. 1-7 buildings because it varies greatly.
Procedure 1, Attach. 1, State BRC plans to recommend shelter-l pp.~1-23 ing only when evacuation is not a..prac-i Procedure 1, Attach. 2, tical alternative.
Evacuation time pp. 1-25 estimates are the responsibility of Procedure 1, Attach. 3, the local government who are decision pp. 1 makers and should factor this in.
Otherwise, bases for protective action recommendations are adequately des-cribed.
J.11.
See Annexes C and L The Departments of Health and Agriculture ADEQUATE to State Plan have been identified as responsible for
-(Previous )
Also see Local Plans actions within the EPZ directed toward (Intdequate) and Appendices 2, 7, control of contaminated products in the (Raco1ved) and 9 to Annex L food chain.
Bureau of Radiation Control, in the 50-mile EPZ, is responsible for Tab 1 Introduction coordination of sample analysis, accident Sect. VII.D., p. 6 assessment and recommendation of protec-Tab 1 Introduction tive response. The functions described Sect. VII.E., p. 7 in this evaluation criteria are clearly Tab 1 Introduction described and appropriately assigned to Sect. VII.F., p. 7 each of the respective agencies mention-Tab 1 Introduction ed above.
State Health Dept. charged Sect. VII.G., p. 8 with ~ developing 50-mile maps showing Tab 1 Introduction locations of dairies and food processing Sect. VII.I., p. 9 plants.
Dept. of Agriculture charged Tab 1 Chapter 2, with developing maps showing food pro-Sect. II.B., p. 3 duction areas and crop types.
m
1
]di: ;*
e; 23.
k CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
)
NUREG CRITERION '
ACTION TAKEN BY STATE i
AND OF TEXAS TO CORRECT-
- EVALUATION CROSS REFERENCES' PREVIOUS INADEQUACIES l'l
?J.11'(cont'd);
Tab 1 : Chapter 2,-
No maps showing water. supplies and res-1' Se ct. III.A.2., p. 4
'crvoirs. Are they available?. Plan dis-Tab 1 Chapter -2, Sect.
cusses. projected. dose commitments at VII.'(last para.),
which protective actions shouldl be taken-p.-18 or considered for milk, other foods ~, and q
Tab 11 Chapter.2, water. Are procedures available for es-i Attach. 6, p. 25' timating the dose commitment based on Tab 1 Chapter 2, known or estimated contamination leve18 '
1
. Attach. 15, p. 43 for other than milk?
Procedure 1 Attach. 1, pp. 1-23.
Actions taken by the State of Texas Procedure 1, Attach. 2,
.pp. 1-25 A map showing surface water reservoirs,-
Procedure 1, Attach. 4, streams and drainage basins within the pp. 1-29 State is mounted in the State EOC and.
was shown to FEMA representatives during' i
our February 19th meeting.
Similar maps are available from.the Texas Water Com-mission and from the Division of Water-Hygiene of the Texas Department of
. Health, as well as maps. showing major; and minor aquifers.- For use with these maps, the Division of' Water Hygiene-maintains:a current computer listing, cross-indexed by county and by geographic coordinates, of all water supply systems,.
their intake structures, and their treat-ment facilities.
Since all public drinking water supplies are routinely sampled by Department'of Health person-nel, we are confident that.the Depart-ment can-adequately _ conduct necessary sampling following an accident at either STPEGS or CPSES.
l
- ,,lb ' l 24.
l l
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
{
NUREC CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT i
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES l
J.ll (cont'd)
Procedures, as noted, are not available.
Cuidance which would permit their de-velopment has not yet been provided by cognizent Federal agencies. We do not l
feel this to be a significant problem, however, because we do not intend to permit marketing of contaminated pro-ducts.
As noted in the cross reference, item 5 of Tab 1, Introductivn,Section VII.D l
states that "The appropriate Division (of The Texas Department of Health, Bureau of Consumer Health Protection) will remove from commerce any contami-nated products, and will supervise their destruction, decontamination or diversion to usages outside the human food chain."
At the same time, through public in-
)
formation and instructions issued via j
EBS and other public media broadcasts, i
the Department will advise the resi-dents of the af fected area not to use food produced for home consumption until adequate sampling and analysis can be accomplished.
ap;"
,=
25.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
-J.
12 Part Two, IV.B.6., p. 6 Registering of evacuees at relocation ADEQUATE Also see Local Plans centers is a local government responsi-Registering: Local re-bility.
State provides monitoring sup-sponsibility port and guidance to local government.
Monitoring: Tab 1, BRC has 10 persons trained to perform Chapter 2, Sect. VI.C.
this task.
BRC has developed personnel 9., p. 15 monitoring and decon procedures.
The 12-hour capability should be addressed in the local plan.
K.3.a.
See Appendix 7 to Annex L State plan will provide, when Procedure ADEQUATE Tab 1 Chapter 1, Sect.
7 is issued, that all Emergency Re.sponse (Previous )
VI.C.4., p. 9 Team members in 10-mile EPZ will have di-
' (Inr.deq ua te)
Tab 1 Chapter 1, Sect.
rect-reading and permanent record dosim-(R;2olved )
VI.C.7. p. 12 etry.
Is this for all State and local Procedure 10, Sect. VIII.
government employees operating as emer-F.,
- p. 7 gency workers? Tab 1, Chapter 2 provides Also see the note at H.ll that Sample Coordination teams will regarding the provisions maintain exposure history for each emer-of Procedure 7.
gency worker.
Contamination Control Teams at Access Control Points will ensure all State and local response personnel have appropriate dosimetry. These teams j
also maintain record of exposure for all l
persons entering exclusion area.
Need j
to discuss the transition to State re-l sponsibility and exposure tracking prior
)
to that occurring.
No 24-hour capability l
and no Procedure 7 to review and evalu-ate.
I Action taken by the State of Texas i
i Tab 1, Chapter 2, item VI.C.7.c., reads:
"To ensure that all state and local re-sponse personnel entering the area (the affected portion of the 10-mile EPZ) are equipped with appropriate personnel
o' i
26.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
' NUREG CRITERION -
ACTION TAKEN BY STATE AND OF' TEXAS TO CORRECT l EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES K.3.a (cont'd) dosimetry." Item VI.C.7.e reads: "To maintain a record of exposure for all persons entering the exclusion area; issuing appropriate direct-reading do-simetry when necessary to accomplish this task."
As evidenced by the above-cited text, the state plan already provides for issuance of appropriate dosimetry to all response team members, and for emer-8ency worker exposure tracking.
P,ro-cedure 7 will simply recap information presently scattered throughout the plan; consolidating it in one location for easy reference.
In response to the need for further discussion relating to transition to State responsibility, the following explanation is given.
Prior to State arrival, exposure tracking is performed by local of ficials using the same expo-sure record form, and the same type of direct-reading dosimetry as will be used by the State.
The transition i
consists simply of State personnel re-lieving locals in an ongoing activity.
I The portion of this comment concerning exposure tracking prior to State arrival should be included in the review of local plans, which have been upgraded to include this function.
i
.,;jd - l
' =
27.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
- NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES K.3.a - (cont 'd )
This comment relating to no 24-hour capability should be deleted for the following reasons:
a.
24-hour capability for all response team functions is adequately docu-mented through statements of commit-ment to conduct 24-hour operations, through provision for 3-shif t posi-tion staffing, and through instruc-tions concerning disposition of '
Emergency Worker Radiation Exposure Record forms' at the end of each shift.
b.
As noted above, the issues to be covered in Procedure 7 are already addressed. Procedure 7 will simply provide an easy, comprehensive reference to all items concerning personnel dosimetry and exposure control.
K.3.b.
See Appendix 7 to Annex L Presumably to be covered in Procedure 7 ADEQUATE Tab 1 Chapter 1, Sect.
once it's developed and issued.
Proced-(Previous -)
VI.C.4., p. 9 ure 7 needs to be reviewed for evalua-(Intdeq ua te) '
Tab 1 Chapter 1, Sect.
tion.
(Recolved )
VI.C.7., p. 12 Procedure 10 Sect.
Procedure 10, page 7 refers to (See VII.F., p. 7 Procedure 7, Personnel Dosimetry and Exposure Records) - Not developed.
Action taken by the State of Texas As identified by the cross-referenced items for element K.3.b., instructions to check dosimeters frequently, and to report the indicated dose as soon as
p r
c
.g.f e '-
28.
+
CONSOLIDATED FEMA /RAC:
REVIEW COMMENTS AND 74 NUREG CRITERION ACTION TAKEN BY STATE d
AND OF TEXAS TO CORRECT EVALUATION-CROSS REFERENCES PREVIOUS INADEQUACIES K.3.b'(cont'd) possible if it ' exceeds - 200 mrem, and instructions for use of the Emergency Worker Radiation Exposure Record form are contained in' Procedure 10,Section VII.F, pages 7 and' 8.
Additionally, s
- l.
those instructions are printed directly Y
on the Emergency Worker Radiation Ex.
j k.
posure Record form which is filled out and carried by each emergency worker.
Both Procedure ~ 10 and the Emergency s
Worker Radiation Exposure Record have
^
already. been issued and are in use by response team members..The exposure record is also in use by local emer-8ency workers, in conjunction with their own specific procedure for per-1 sonnel dosimetry and exposure control.
As noted in the preceding response to K3.a., Procedure 7 will be issued, but its impact'will not be to impose new guidance.
Rather, it will consolidate existing guidance in one procedure for ease of reference.
For these reasons, we do not feel that review of Procedure 7 is essential to "1-the rendering of a finding of adequacy for element K.3.b.
I I
4
.,g-C*
, el
(*'.
L 29.
CONSOLIDATED FEMA /RAC
, 1
- REVIEW COMMENTS.
.AND
. NUREG CRITERION ACTION TAKEN BY, STATE
.AND.
OF TEXAS TO CORRECT' IEVALUATION-CROSS REFERENCES PREVIOUS INADEQUACIES
. K. 4 -
See' Appendix 7 to State plans iadvise if PAGs have to' be' 1 ADEQUATE Annex L exceeded., The Mayor,. County Judgefat i
' Procedure 1,-Section.
local' level,' or Governor (or his au-
.VII.A.3.b.(6), pp.'l-6 thorized representative) at State-Procedure 1, Section level must authorize it.
VII. A.4.b. (2)(c), pp. 1-9 Procedure'10,.Section VIII.F.5., p. 8
[As. evidenced by the above, we do not intend to permit excessive exposures:on a prior approval basis. The number of persons available
. within'the State and: local response organizations will almost always allow rotation of personnel with sufficient frequency to keep individual' exposures well below 25 Rem.
In the ' event-that exposures '
in' excess of PAGs are necessary
' for the purpose.of conducting lifesaving or.other essential activities, authorization must be obtained from the principal elected. official of the juris-diction involved (or his des-
- ignated representative), and
. the. activity must be under-taken with the informed con-sent of.the individual (s)-in-volved. See the following reference.]'
C Procedure 1, Sect. VII.A.4.b.
(2)(c), pp. 1-9 a
J
r L.gdil ;i i
'30.
j i
1 1,
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND s NUREG CRITERION ACTION TAKEN BY STATE
=AND OF TEXAS TO CORRECT
. EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES-LK,5.a.
See Appendix 7 to Annex L State Plan and procedures adequately ADEQUATE Facilities:
Procedure 1, addresses action levels requiring need i, pp. 1-33.
for decontamination.
Equipment:
Procedure 4, S,ect. VIII., pp. 4 Clothing:
Procedure 5, Sect. IX.A., p. 14
-Personnel:
Procedure 5, I
Sect. IX.B., p. 14 K.5.b.
See Appendix 7 to Annex L Means are provided for waste disposal.
ADEQUATE Tab 1, Chapter 2, Sect.
Contamination team will monitor and II.A.3.,~p.
2 direct, as necessary, the decontamina-Tab 1, Chapter 2, Sect.
tion of workers, impound or direct de-l VI.C.7.f.
- p. 13' contamination of contamination vehicles Tab 1, Chapter 2, Sect.
or. equipment. Team will retain custody VI.C.10., p. 16 of all contaminated waste until proper -
Procedure 4, Sect. VII.,
disposal (by HL&P) can.be accomplished.
- p. 4-2 Actual decontamination is responsibility.
Procedure 5, Sect. VIII.,
of local government but Bureau teams are
- p. 6 trained and equipped to provide " super-visory guidance" to local monitoring teams at reception centers.
Decontami-nation procedures list the equipment necessary to perform decontamination of various surfaces.
L.1.
See Local Plans and Tab 1, Chapter 2 refers to Matagorda ADEQUATE-Appendix 7 to Annex L General Hospital in Bay City and Wagner General Hospital in Palacios Tab 1, Chapter 2, Sect.
as the two local designated medical VI.C.10., p. 16 facilities. The State will dispatch Procedure 5, Attach. 2, a trained State Medical Facility
- p. 21-Liaison Team to assist the hospitals.
The plan should clearly designate Matagorda General Hospital as the i
primary, and Wagner General as the back-up, medical f acility.
d
)
l 1
J 1
- g ~f f
+
4.
31.
i L
CONSOLIDATED FEMA /RAC
{
REVIEW COMMENTS AND
' NUREG CRITERION ~
ACTION TAKEN BY STATE:
JWIE OF TEXAS TO~ CORRECT.
I EVALUATION-CROSS REFERENCES PREVIOUS INADEQUACIES-l L.3'
.See Appendices.3, 11 and Procedure 5 includes a' list of medical
' ADEQUATE 12 to Annex L support facilities providing name, lo-(Frsvious- )
cation and bed capacity.. Does not T (Inadeq ua te) '
Procedure 5, Attach. 2, denote type of. facility (i.e. private, (Resolved. )-
- p. 21-state, military, etc.).
This list does not indicate the ambulatory /non-ambula-tory capacities for providing medical support 'for " contaminated ' injured" members of the general' public and any special ' radiological capabilities as per GM-MS-1.
The need for_more detailed guidance has been. discussed with FEMA National. Until this additional' detailed information is received, Region VI. is evaluating this element as adequate.
Action taken by the State of Texas Hospitals listed in Procedure 5 in our plan are there because.they have' at least some degree oficapability in the desired areas.. It is the responsibility of the attending physician or the referring.
hospital to' contact the receiving facil-ity in order to' ensure that the patients' specific needs can be met. We will an-notate the list of facilities to show whether they are private, state, military,-
etc.
While we do not feel that they will add anything to state response capabilities, letters of agreement will be solicited '
from the hospitals currently listed'in to Procedure'5.
Letters of agreement from' appropriate additional facilities will be incorporated in the State Plan when= FEMA identifies a J'
measurable standard which they consider to be acceptable.
n
Y P.'
32.
\\
CONSOLIDATED FEMA /RAC REVIEW COMMENTS
)
AND NUREG CRITERION ACTION TAKEN BY STATE I
AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES L.4.
See Local Government Emergency transportation of victims N/A Plans is a local respnsibility to be ad-dressed in local plans.
M.1.
Basic Plan Part III Plans and procedures for re-entry and ADEQUATE (all) (pp. 1-5) recovery and means by which de'cisions to relax protective measures are j
Tab 1, Chapter 2, Sect.
covered in state ref erences to the VI.C.3., p. 9 plans.
Tab 1, Chapter 2, Sect.
)
VI.C.4., p. 9 i
Tab 1, Chapter 2, Sect.
VI.C.4., p. 11 Procedure 1, Sect. VII.A.,
pp. 1-2 1
Procedure 1, Sect. VII.B.,
pp. 1-10 Procedure 1, Sect. VII.D.,
i pp. 1-20 Procedure 10, Sect. X, p. 10 Procedure 10, Sect. XI., p. 15 (While the above ref-
)
erences do not describe a specific plan for re-entry, they do identify the process by which decisions concerning re-entry are to be made.
In general, until the EPA's PAGs for relocation are issued in final form, reentry will be permitted when exposure levels and dose projections fall be-
)
low the PAG 1evels which
,, r <
' (i 3 3. '
1 CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND i
NUREG CRITERION ACTION TAKEN BY STATE
)
AND OF TEXAS TO CORRECT
, EVALUATION-CROSS REFERENCES PREVIOUS INADEQUACIES M.1. (cont'd) initially triggered the protective response (s).
Once Chapters 4 and 7 of the PAGs are issued j
in final form, the State's position on reentry and recovery will be reevalu-1 ated and any. warranted changes will be incorpo-rated in state plans and procedures.)
M.3 Basic. Plan, Part Three, Chief of the Bureau of Radiation -
ADEQUATE III.B., IV.B & V. pp. 3, Control is responsible for notifi-5&6 cation to response organizations Also see Part Three, concerning emergency operations
' Attach. 1, p. I being phased down or concluded.
Appendix 7, Sect. VII.A.
This would be accomplished through 2., p. 8 the communications network.
-M.4 See Appendix 7 to Annex L Procedure 1 describes method for ADEQUATE' Procedure 1, Sect. VII.C.,
estimating total population ex -
pp. 1-20 posure. Does not mention how frequently this will be done.
Should be done " periodically" and should be mentioned during next plan revision.
~N.1.a.
See Appendix 7 to Annex L The State Plan, Tab 1 for Nuclear f acili-ADEQUATE Tab 1 Introduction, Sec.
ties sets forth criteria for exercising Sect. II.A. of Attach. 4, in accordance with FEMA requirements.
- p. 20 N.1.o.
See Appendix 7 to Annex L Plan requires that exercises be scheduled LADEQUATE Tab 1 Introduction, to prove capability to implement response Sect. II.A. of Attach. 4, during any hour and in any type weather.
- p. 20 l
r
.,t*.
.,e 34.
I CONSOLIDATED FEMA /RAC REVIEW COMMENTS l
AND NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES N.2.s.
See Annex L, R and AA State Plans (attachment 4, p. 21) pro-ADEQUATE Also see Appendix 7 to vide for testing monthly the ability i
Annex L of the State system to receive a simu-Tab 1 Introduction, lated message from each utility and Sect. II.B.1. of relay it to DPS District Office through Attach. 4, p. 21 DPS. Headquarters communications, the 1
DEM and the Dept. of Health's Disaster Response Program to the BRC.
Includes j
message being transmitted in an under-standable form.
N.2.d.
See Appendix 7 to Annual drills as required by this element ADEQUATE Annex L are provided for by team participation in Tab 1 Introduction the annual exercise of the respor se plan.
Sect. II.C.4. of Attach.
4,'p.
22 N.2.c.
See Appendix 7 to Plan provides for semi-annual drills for ADEQUATE Annex L each 4-man shift of the Accident Assess-Tab 1 Introduction ment Team.
i Sect. II.B.2. of Attach. 4, p. 22 N.3.a.
See Appendix 7 to Plan states that exercises will be in ADEQUATE Annex L acordance with FEMA requirements.
j Tab 1 Introduction i
Attach. 4, pp. 20-21 N.3.b.
See Appendix 7 to Plan states that exercises will be in ADEQUATE
. Annex L acordance with FEMA requirements.
{
Tab 1 Introduction i
Attach. 4, pp. 20-21 i
s-
,g,34
,y,
- W 7
- 35, i
CONSOLIDATED FEMA /RAC REVIEW COMMENTS
- AND-
. NUREG CRITERION ACTION TAKEN BY STATE AND OF TEXAS TO CORRECT
' EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES N.3.c.
- See ; Appendix 7 to
~ Plan states that exercises will-be -in1
~
'-ADEQUATE Annex L acordance with FEMA requirements.
Tab-l' : Introduction-At tach. 4, pp. 2 0,
1 JN.3.d.-
See Appendix - 7 to Plan states that exercises will be in j
' ADEQUATE-Annex L acordance with FEMA requirements.
1 Tab 1, Introduction Attach. 4, pp. 20-21 N. 3.'e -
See Appendix 7-to Plan states that exercises will be, in j
ADEQUATE.
Annex L acordance with FEMA requirements.
l Tab 1 Introduction
'l Attach. 4, pp. 20-21
'l
)
N.3.f.
See Appendix 7 to Plan' states that exercises will be in i
ADEQUATE-Annex L acordance with FEMA requirements.
Tab 1 Introduction Attach. 4, pp. 20-21 N.4.,
See Appendix 7 to The plan recognizes that' Federal Evalu-
- ADEQUATE Annex L ators as well as State and Local Govern-Tab 1 Introduction, ment representatives will evaluate the-Sect. II.A. of.
exercises.
Attach. 4, p. 20' N.5 See Appendix 7 to Following each exercise, a critique j
ADEQUATE Annex.L will be conducted, observer comments
.)
Also see Anner.es to. the will be evaluated, necessary changes 1
State Plan to appropriate plan elements will be Tab 1 Introduction, incorporated, and plan updates will-Sect. II. A. of Attach.
be issued.
4, p. 20 Ap pe ndix 7, Se ct. ' XI. A.,
- p. 26- ~
Appendix 7, Sect. XI.D.,
- p. 27
.g
US 36.
a,
+
CONSOLIDATED FEMA /RAC l
REVIEW COMMENTS AND j
NUREG CRITT,RION ACTION TAKEN BY STATE 3
AND OF-TEXAS TO CORRECT 1
EVALUAT7JN CROSS REFERENCES PREVIOUS INADEQUACIES t
0.1 Tab 1 Introduction, State plan adequately covers the kind ADEQUATE.
Attach. 4, pp.17-20 of training to be offered to appropri-ate State individuals.
0.4.a Annex AA, App. VI Training established for directors or ADEQUATE Tab 1 Introduction, coordinators of the State response Sect. I.A. of organizations.
Attach. 4, p. 17 0.4.b.
See Appendix 7 to Training established for personnel ADEQUATE Annex L responsible for accident assessment.
Tab 1 Introduction, Sect. 1.B.3. of Attach.
4., p. 18 0.4.c.
See Appendix 7 to Training established for radiological ADEQUATE Annex L monitoring teams and radiological Tab 1 Introduction, analysis personnel.
Sect. I.B.4. of Attach. 4, p. 18 Tab 1 Introduction, Sect. 1.B.5. of l, p. 18 0.4.d.
Part One, Attachment 5, Texas Engineering Extension Service ADEQUATE
- p. 33 assigned responsibility for training Also see Annexes R and of fire fighting personnel, law en-FF forcement, security training covered Annex AA, APP. VI.
in Annex R.
Also see Local Government Plans 0.4.f.
See Local Government This is a local responsibility.
N/A Plans
n;
~~
f!%A J
37.
t CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTION TAKEN BY STATE AND-0F TEXAS TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES O4.h.
See Annex L and Local This is a local responsibility but the
' ADEQUATE Plans State personnel assigned as Medical Fa-Tab 1 Introduction, cility Liaison Team will complete the Sect. I.B.8. of Oak Ridge courses and re-training as Attach.
4,'p.
19 identified during exercises. Medical support personnel training covered adequa tely.
'O.4.J.
See' Annex R and State personnel responsible for trans-ADEQUATE
. Appendix 7 to Annex L mission of emctgency information and instructions set forth in Annex R.
0.5 Appendix 7 to Annex L, Procedures set forth for ; initial and.
JADEQUATE
- p. 23 annual training of personnel with Tab 1 Introduction, emergency response responsibilities.
Sect. VIII., p. 9 Tab 1 Introduction, Sect. I.A. of Attach. 4, p. 17 Tab 1 Introduction, Sect. I.B. of Attach. 4, p. 18 P.1.
See Annexes Training of individual responsible' for ADEQUATE Tab 1
. Introduction, planning ef fort set forth.
Sect. I.B.1. of Attach. 4, p. 18 P. 2.
Preamble (p. ii)
Director, Division of Compliance and
-ADEQUATE Also see Appendix 7 to Inspection has overall authority and Annex L res ponsibility.
Appendix 7 Sect. XI.A.,
- p. 26 P.3.
Preamble (p. ii)
Manager, Emergency Response Planning ADEQUATE Part 1, VII.C., p. 8 Program has the responsibility.
Appendix 7, Sect. XI.A.,
- p. 26 l
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.38.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
' NUREG CRITERION ACTION TAKEN BY STATE
.j EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES.
j AND' OF TEXAS TO CORRECT j
1
-P.4.
Part 1, VII., p. 8 Proced'ures set forth to update plan,
, ADEQUATE-See Annex AA, Appendix 7, etc. as needed.
]
Sect.
XI.D., p. 27
]
q P.5.
See Annexes Procedures set forth for changes to l
ADEQUATE Appendix 7, Section plans to be forwarded to all parties XI.B., p. 27 concerned.
Appendix 7', Section 1
XI.D., p. 27
-P.6..
Part One, Attach. 4, Sets out supporting plans and their ADEQUATE
- p. 1 sources.
Appendix 7,Section I.A.,
- p. 1
~
Appendix 7, Section j
I.B.,
- p. 1 l
Tab 1 Introduction, Sect. IV., p. 1
. Tab 1 Introduction l
Attach. 1, p. 11 l
i P.7.
State Plan is a master Procedures and implementation set ADEQUATE document implemented as
- forth, a whole Appendix 7 Procedures Manual -
J J
Procedure Index, p. ii P.8-Page 1 of each section Table of Contents and Cross Reference j
ADEQUATE Appendix 7 Table of included in Plan submission.
Contents, p. 11 Tab 1 Introduction, Table of Contents, p. i Tab 1 Chapter 2, Table of Contents, p. i.
Procedures. Manual, Pro-cedure Index, p. 11
)
P.10 Part Two,'V.A., P. 7 Telephone numbers to be up dated at i
ADEQUATE Annex AA, B.V.3., p. AA2 least quarterly.
Appendix 7 - Next to last i
statement on Attach. 5,
- p. 38
1:
9 M ;4 g c
["
May 29,L1987
.+ c 4--
l H
FIRST INTERIM FINDING ON SOUTH TEXAS PROJECT ELECTRIC GENERATING-
. STATION (STPEGS) 0FFSITE RADIOLOGICAL, EMERGENCY PREPAREDNESS d
MATAGORDA COUNTY PLAN i
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND :.
ACIIONS TAKEN BY MATAGORDA
'NUREG CRITERION
. COUNTY TO CORRECT AND' PREVIOUS INADEQUACIES 4
EVALUATION:
CROSS REFERENCES A.1.a.
Plan Sect. V (10/28),
County' plan identifies only ' the. local'
< ADEQUATE-Annex W Attach.'1,
- organizations and officials in the re-(Previous. )
Annex W Sect. V (W-sponse organization'
'No State, Federal
- 1
-(Inadequate) 16/W-34) or other organizations. (except utilities)
- 1
{
(Resolved.-)
are shown.-
Action taken by Matagorda County has been added'to the
)
County plan to illustrate how the
]
elements of the' emergency plan fit j
together.
See Manual of Emergency Procedures, Attachment M.
Also, Attachment 4 was revised in re-vision 2 of the County' Plan.
c A.1. b..
Plan Sect. IV (6/9),
County Judge and Mayors, as chief elected ADEQUATE Plan Sect. V (10/28),
officials, are responsible for all emer-(Previous )
Annex W Sect. V (W-gency measures within their jurisdictions (Inadequa te) 16/34)
Assignments of. responsibility begin on (Resolved)
Annex W Sect. IV Plan page 10.
Plan Sect.'IV describes (W-13/16), Annex W operations under specific conditions.
' ha imil-l--
ama am m isill
G wa..(s{; s :
- s 1 :
. 4
- 2. -
1 CONSOLIDATED FEMA /RAC.
REVIEW COMMENTS AND NUREG CRITERION.
ACTIONS TAKEN BY MATAGORDA LAND-COUNTY TO CORRECT.
EVALUATION-
' CROSS REFERENCES PREVIOUS INADEQUACIES A.1.b (cont'd),. Tab 1 Annex W, Sections IV and V describe con-Sect. IVl(W-1-7/13),.
' cept of operations and task assignments -
Tab 2. Sect. IV (W-2-5/~
for fixed nuclear facility response.
11),, Tab 3 Sect;III (W-3-3/16), Tab"4 Recommend that additiona1' information-l Sect. III (W-4-2/5),
be added ' clarifying the: coordination of Tab 5 ' Sect.: III (W-5--
direction and control actions between 2/6)', Tab 61 Sect III the County Judge an<d City Mayors.
.(W-6-2/8), Tab 7 Sect.
IV (W-7-4/8), Tab 8 Several other inadequaciesL in this-finding have, as'their root caus~e, the Sect. III-(W-8-2/7),-
inconsistent relationships between these -
Tab 9 Sect. IV (W elected officials, and the apparent 1/4)-.
multi-headed control system.
Procedure 2, p. 12 of.
56
. Action taken by Matagorda County Manual of-Emerg. Pro-Implementation of the Matagorda County
.cedures,Section I Emergency Management Plan'is the re-(Preface) sponsibility of the elected chief executives of Matagorda County, the City of Bay City, and the City of Palacios. Each official will direct the~ conduct of operations within the
' jurisdiction for which he.is responsi-
.ble.
In addition to strictly county-level operations, the County Judge will serve as overall coordinator when several or all of the above jurisdic -
tions are involved in response activi-ties. For response to events at STPEGS, the County Judge is responsible because the EPZ is under the jurisdiction of the County.
i
.;,.. 3 33.-
A i
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CFOSS REFERENCES PREVIOUS INADEQUACIES A.1.c.
. Plan Attachment 1 The County Emergency Organization Chart ADEQUATE (block diagram) illustrates the local
{
emergency organization.
i
~
A.1. d. -
Plan Sect. IV.A. (6/7)
Senior officials.of each organization ADEQUATE Plan Sect. V.A. (10/12) are designated by title, as responsible for eletnents of the emergency response.
A.1.e.
Plan Sect. IV.C (8)
Responsibility assigned to each organi-
' ADEQUATE Plan Sect. V.B.3.a (15) zation to develop and maintain 24-hour operational capability, including'24-
~
hour communicatioc. links to services, State, Federal and other agencies.
County ' Sheriff's communications center is the communication base for the s
locality.
]
A.2.a.
Plan Sect. V (10/28),
Functions and responsibilities for major ADEQUATE Annex W Attachment 1, elements and key officials, by title, are
~TPrevious )
Annex W Sect. V (W-16/
specified for all emergency response ac-(Inadeq uate) -
34) tivities.
(R2 solved )
We suggest' the following changes be made to clarify or correct Plan / Annex sections related to this element:
q
- Rewrite paragraph VII.C (p. 33 of Base Plan) to clarify channels for requesting Federal assistance
,.i
'4.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATACORDA AND COUNTY TO CORRECT L
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES A.2.a (cont'd)
- Rewrite paragraph.III.B.2 (p. W-4-3) to indicate Co. Judge coordination.
- f with appropriate Mayors prior to. dis-tribution of PAR's to the public.
- Make the following changes / additions to Attachment 1, Annex W,'to make the chart conform to the texts:
+ Indicate under title of Attachment; "As Delegated by Senior El,ected Of-ficials of Matagorda County".
+ Add another line for "Public In-formation Officer" and a
'P' on this line under Emergency Public Information.
+ On the " State" line, change the
'S' to a
'P' under Accident Assess-ment to coordinate with the text on
- p. W-24.
Also, add 'S's under Traffic Control and Law Enforcement.
Indicate with a
'P' that the State l
has primary role in Social Services.
+ On the " Red Cross" line, add an
'S' under " Social Services".
+ Under the " Radiological Exposure
]
Control" column, add 'S's to the
" County Sheriff", " Fire Chiefs" and "Matagorda Co. Hospital Dist.
Admin." lines.
i
+ On' the " School Superintendents"
)
line, add an
'S' under " Protective Res pons e".
I I
i 9
f
~
l
(
5.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES A.2.a (cont'd)
Action taken by Matagorda County t
Paragraph VII.C of the base plan has been revised to include the following:
Requests for State or Federal assistance will be placed with the State Disaster District Sub 2A Headquarters in Pierce by the Emergency Director or in his name by other officials specifically cuthorized by him.
When a need for assistance is identified by any of the Emergency Management Organization response groups, that in-formation is to be forwarded to the Emergency Director.
]
Paragrapa III.B.2 Tab 4 (p. W-4-3) has been revised to include the following:
)
If the Judge agrees with the recommended protective action, a message will be developed and transmitted to the general public over the Emergency Broadcast Sys-tem (EBS) station (s) in Bay City. The appropriate Mayor (s) will be notified if City resources may be needed to support an evacuation. Neither of the two in-corporated cities are in the EPZ., Annex W will be revised to reflect the recommended changes except that the State does not have a primary role in social service.
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L6.C
- E
CONSOLIDATED' FEMA /RAC REVIEW COMMENTS.AND NUREG ' CRITERION ACTIONS TAKEN BY MATAGORDA lAND COUNTY TO CORRECT.
EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES DA.2.b:
Plan Sect. I (1)
Part'I, items A through L,' list.the' legal, ADEQUATE.
authorities.for the plan..and operations
. under f the plan.
TA.3 Plan Attachments 3,
'The plan does.not include Letters of-
' ADEQUATE.
4, 5, - 6 a nd ' 10 -
Agreement with Mid-Coast Cable - TV,' The-
.(Previous. )'
Blessing VFD.; The Matagorda.VFD or.a
. (Inadeq ua te)"
copy'of.the contract with Taylor Bros.
l(Rasolved)'
Ambulance' Service. 'It-also-does not-include; agreements with The Matagorda Co.. Amateur Radio Club for;back-up com-
.munications.
Action-taken by Matagorda County' A Letter of ' Agreement with Mid-Coast
~;
Cable TV has been provided.
A Letter of Agreement with Matagorda
'f VFD has been provided.
-j A Letter of Agreement with Blessing j
VFD;has been provided.-
A copy of the Letter of. Agreement with Taylor Brothers Ambulance Service has
]
.been provided.
A Letter of Agreement.with Amateur Radio Club has been provided.
( A. 4 '
Plan Sect. IV.C (8)
Plan ~ assigns responsibility to organi-ADEQUATE Plan Sect..V (10).
zations (by title.of individual) for, developing capability for " extended period" 24-hour operations.
i l
i 1
i a
s 7.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND I
NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES C.1.c Plan Sect. IV.B (7/8),
Responsibility for this element con-ADEQUATE Plan Sect. III.A (2/5),
cerning specific resources for Federal Tab 2 Sect. III (W-2-2/
response is assumed by the State. How-5) ever, the plan does list certain support resources.
C.2.a Tab 9 Sect. IX.A.3 (W-Local representative "may" be dispatched ADEQUATE 9-6) to STPEGS EOF if desired.
C.4 Plan Sect. VIII (34),
Resource controls may be imposed by Co.
ADEQUATE Plan Sect. V (10/28),
Judge / Mayors. All resources, public and (Previous )
Plan Attachment 10 private, may be used by local officials (Inadequa te) if deemed necessary - no financial lia-(R: solved
)
bility is assumed.
Letters of agreement with EBS stations, ISD's, VFD's and ARC are included. However, some LOA's (as 1
noted in A.3 above) are missing.
l Action taken by Matagorda County All listed Letters of Agreement have been provided, as discussed, in response to A.3.
D.3 Plan Sect. VI (28/34),
Annex W adequately describes the four ADEQUATE Annex W Sect. VI (W-levels of Emergency Classification (ECL's)
(Previous
)
34/39) that are consistent with State and Utility (Inadequate) classification systems.
In the County (Rssolved
)
plan the ECL's are a single purpose sub-system under the overall " Increased Readiness Condition" classification sys-tem designed for response to any emer-gency.
p
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~
CONSOLIDATED FEMA /RAC REVIEW. COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND.
COUNTY T0 CORRECT' EVALUATION CROSS REFERENCES' PREVIOUS INADEQUACIES
]
'D.3 (cont'd)'
~This-dua1' classification situation could, unless,all personnel are fully trained and!
j aware of the situation, result in confu-sion or misinterpretation of an. emergency 1
situation.
]
q Action taken by Matagorda County.
-The Increased Readiness Conditions ~ des-D cribed in Section VI of the plan cover a11' emergency-related events that may effect Matagorda County. The ' Emergency.
Classifications described in Annex W are' unique. to events involving' the 1
STPEGS and are covered under' the In-creased. Readiness Conditions. Train-ing is provided to emergency response.
personnel. Annex W has been revised to remove references to Increased -
- ]
Readiness Conditions.
Also, see response to D.4
- D.4 Plan. Sect. V.B. (10/28),
Procedures 1 thru 11, designed under the j
EADEQUATE.
. Plan Sect. VI.(28/34),
Plan's "All Hazards" approach, provide-
.(Previous: ).
Annex W Sect. VI (W-34/
for emergency actions based on the "In-(Inadequate) 39), Plan Attachment 8 creased Readiness Conditions". Emergency "g,(R$ solved; )
(Procedures 1 thru 11 Classification Levels are mentioned in should be added) the procedure texts but we feel that there is significant possibility for q
confusion due to the dual classification systems.
We, therefore, recommend that a separate set of procedures, specific l
u a
La
.;e
..a;.
9.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND
-l NUREG CRITERION ACTIONS TAKEN BY MATAGORDA l
AND COUNTY TO CORRECT EVALUATION ~
CROSS REFERENCES PREVIOUS INADEQUACIES D.4 (cont'd) to Annex W, be developed. These pro-cedures should be based on the four J
Emergency Classification Levels re-quired by NUREG 0654 criteria, and as developed for the local plans related-to the Comanche Peak Nuclear Plant.
l Action taken by Matagorda County A Manual of Emergency Procedures for Incidents Involving the South Texas Project Electric Generating Station has been developed.
'E.1 Plan Sect. VI (28/34),
See recommendation under D.4 above.
ADEQUATE Annex _W Sect. VI (W-34/
Procedures describe (generally) what is (Provious )
39), Annex W Sect. V.b.
to be done, and who is to do it.,But, (Intdequate) 2 (W-18), Tab 1 Sect. IV no description of how it will be done is-
!(Resolved
)
(W-1-1-7/12) included. No verification scheme is (Procedure 03 and 04 shown in the plan.
should be added)
Action taken by Matagorda County A Manual of Emergency Procedures for Incidents Involving the South Texas Electric Generating Station has been developed. Procedures for verifica-tion are provided in Attachments C and D of this manual.
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o L:
1100 a CONSOLIDATED-FEMA /RAC REVIEW. COMMENTS AND NUREG CRITERION.
ACTIONS TAKEN BY MATAGORDA AND.
COUNTY TO CORRECT.
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES LE.2 Plan Sect. V.B.2.d (14)
See D.4 and E. 1 above.- Material-in-
-ADEQUATE'
. Tab 1 Sect. IV (W-1-7/
.cluded in Annex W Tab 1'related'to (Previous )
12) alerting -and mobilizing emergency staf f
,(Inadeq ua te)
(Procedure 03 should be should be included in ' procedures. We (Rasolved)'
added) also recommend that EOC staff alerting
' lists be ' staged':so as to-call appro-priate staf f at each Emergency.Classi-fication Level.
~
Action taken by Matagorda County
-A call list of personnel with. telephone numbers will be maintained in the Mata-gorda County Sheriff's Office. The Manual' of Emergency Procedures has been revised to include a reference to this call list in Attachment E.
Attachment E shows a staged call-out.
E.5
-Annex W Sect. V.C (W-19/-
Procedure 4 indicates EPI responsibili-
' ADEQUATE 20),' Tab 1' Sect. IV.E ties assigned to Co. Sheriff and Chief (Previous, )
(W-1-11/12), Tab 2 Sect.
of Police. No indication on Attachment (Inadeq uat e) '
III.D (W-2-4), Tab 5 1 to Annex W, or on page W-21, o; the
.(R2 solved.)
(W-5-1/14)
-role of the Chiefs of Police in EPI.
Responsibility of PIO (described in Tab 5) is not reflected in the Plan or Annex.
Action taken by Matagorda County-Procedure 4 has been superseded by.the Manual of-Emergency Procedures,Section VII, with responsibility assigned to the Public Information Officer. Emer-
.e
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1
., 11.-
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIO.NS TAKEN BY MATAGORDA EV L ATION CROSS REFERENCES PREVIO S INADEQ A ES 1
E.5 (cont 'd)'
gency ' Public. Inf o rmation -is the _ respon-
.)
sibility of the Emergency Director and he will designate a Public Information
' Officer. Annex W. Section:V.D:(page'20-
- 21) has been revised to. indicate-that:a:
Public Information Officer _.is~ designated.
The Public Information Officer will'be normally assigned toiserve at the Media -
-Center as an interface.with'the County EOC.
Chief s of. Police do not have a ' specific l
role in EPI.
E.6 Plan Sect. V.B.2 (14),
' ADEQUATE Annex W Sect. V.C (W-19/.
County sheriff assigned responsibility.
'to maintain 24-hour capability to dis-
?j 20), Tab 1 Sect. III.A/C seminate notification.to the public j
(W-1-2/5) within 15 min. of. initial receipt.
.J Sirens, tone alert radios..EBS, cable I
J/;
television and other.available systems.
)
J/, /
are to be used.
1 ue 1
s
'^
-E.7 Plan Sect. V.B.14.d (24),
Responsibility assigned to Co. Emergency j
' ADEQUATE Annex W Sect. V.D.9 (W-Coordinator to provide the public with 1
- (Previous
)-
23),- Tab 5 Attachments information on protective actions.:
(Inadequa te) 1/3 (W-5-8/14)
(R3 solved
-)
Pre-scripted messages in Procedure 4, pages 8-10, are not consistent with Emergency Classification Levels. -No definitions of meanings of "(Major /Some/
Minor /No) significance" on Attachment l' to Tab 5 (p. W-5-8).
Is this the same as Tab 1 Chapter 2 Section IV.p. 6 of the State Plan?
I i
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- 12.-
'l
- )
. CONSOLIDATED FEMA /RAC'
. REVIEW COMMENTS'AND-L NUREG CRITERION ACTIONS TAKEN BY MATAGORDA-
'AND-COUNTY TO CORRECT
!c EVALUATION
' CROSS REFERENCES PREVIOUS INADEQUACIES E.7;(cont'd)
Action taken by Matagorda. County Pre-scripted. messages'have been re >
written to resolve this~and.are in-cluded in the Emergency Procedures Manual as Attachment' N, 0,.and ' P.
1
(
1 J F.1. a.
Plan Sect..V.B.3.a (15),.
Responsibility ' assigned to sheriff. and-i
- ADEQUATE Annex W Sect. V.B. (W-18/-
police chiefs to. establish and ' maintain 19), Annex W Sect. V.C-24-hour. communications links to ill (W-19/20),. Tab 1 Sect.
other appropriate agencies / locations.
IV.E (W-1-11/12)
Both primary and alternate-links are
{
illustrated.
.l
- F.1.b Tab 2 Sect. IV (W-2-5/
Telephone and radio 1 inks are in place
~
ADEQUATE 11) to communicate with the State and ad-jacent-local jurisdictions.
F.1'. c Tab 2 Sect. IV.C.3 Local communications to Federal levels 1
ADEQUATE (W-2-6) is, by design, through..the State Dis-
)
aster District and the State E00.
' F.1.d -
Plan Sect..V.B;3.a (15),
Dedicated telephone lines connect the ADEQUATE Annex W Sect. V.B.6 (W-EOF with the State Sub-district EOC i
19), Tab 2. Sect. IV.A/D (Pierce) and the local E0C.
Communi-(W-2-5/6), Tab 2 Fig.1, f eations to the Field Monitoring teams
-l (Procedure 5 should be
'is via the law enforcement radio system.
1 added) j
o q
- [..
?
I. l 13..
CONSOLIDATED' FEMA /RAC
.i N
REVIEW COMMENTS AND t'
NUREG CRITERION ACTIONS TAKEN BY.MATAGORDA
-AND-COUNTY.TO CORRECTS EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES a:
[F.1.e :
Plan Sect. V.B.2.d (14),
'See recommendation under D.4 above', and ADEQUATE Plan Sect. VI (28/33),
comment under E.2.
(Previous
~)
Tab 1 Sect..IV.E (W -
~
j
'(Inadequate) 11/12)-(incorrect on Alerting lists are ' incomplete and do j
(Rasolved )
cross-ref. list) not reflect alternate personnel for
]
(Procedures 03 and 05 24-hour manning.
should be added)
.]
' Action taken by Matagorda County J
A list of personnel and their [ telephone numbers, including alternate ' personnel to i
enable 24-hour manning, will;be maintained at.the Matagorda County Sheriff's Office.
- j Alternates for key personnel ~are listed 4
in the Emergency Procedures Manual.
F.2_
Annex W Sect. V.B.6 (W-service by telephone and a radio link
-l Plan Sect. V.B.3.a (15),
Communication. to hospitals. and ambulance.
. ADEQUATE betwe'n the ambulance _and'the hospital 19), Tab 2 Sect. - IV.G e
(W-2-7/8)
'or the county sheriff's office.
'F.3 Plan Sect. V.B.3.a (15),
Plan calls for monthly tests of communi-
" ADEQUATE Annex W Sect. V.B.4 (W-cation systems.
19), Tab 2 Section IV.I/J
.(W-2-8/9)
(Procedure 11 should be added)
.i G.1" Plan Sect.-V.B.14.a (23),
County Coordinator assigned responsi-ADEQUATE Annex W Sect. V.D.1 (W-bility to establish and maintain an 21) annual EPI program ' incorporating all (Procedure 04 should be
- of:the factors listed in the criteria.
added)
]
i 1
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'1,:
3 l..
.e L'c 114.1 CONSOLIDATED FEMA /RAC-REVIEW COMMENTS AND i
NUREG CRITERION'
' ACTIONS TAKEN BY MATAGORDA JAND:
- COUNTY TO CORRECT EVALUATION-CROSS REFERENCES PREVIOUS INADEQUACIES-h G.2J Plan Sect. V.B.14.b (23)
Plan calls for an annual update 'and -
ADEQUATE Annex W' Sect. V.D.1L(W-dissemination of EPI material for 21)'
. resident and transient populations (Procedure 04 should be within'the plume EPZ.; Recommend' added) _
- p. W-21 specify delivery of written; material to each residence within:
.the EPZ.
Even though G.2 was evaluated as adequate, the following action was taken by Matagorda County for,sug-gested improvement to the plan.
Action taken by Matagorda County Annex W,Section IV.D.1 (W-20) has been revised to specify annual de-livery of written material ~ to each residence within the EPZ.
- G.3.a Plan Sect. V.B.14.d (24)
Plan says that the County Coordinator ADEQUATE Annex W Sect. V.D.4-(W-shall conduct an annual training pro-'
(Previous )
22), Tab 5 Sect. III.b gram for the media that includes de-
' (Inadeq ua te)
(W-5-4) signation of ~ points of_' contact. No
-(Rasolved' )
locations for news media use are des-ignated in ' the plan.'
Action taken by Matagorda County Reference to the Media Information g,
Center has been included in' Annex W,
-j f
Section V.D.6.(W-22).
This facility is J
operated as a joint information center by STPEGS in Alert and higher classi-fications.
1.
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CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND-NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
'G.4.a, Plan Sect. V.B.14.d (24)
The Annex 'and the Tab are in conflict-
- ADEQUATE ~
Annex W Se ct. ' V.D. 6 (W-
' in the, designation of the locality's'.
(Previous, )
23), Tab 5 Sect.'s III.
of ficial spokesperson.
(Inadequate)
'B.1/2 (W-5-4)
(Rssolved
')
Procedure 4 p. 3 Action taken by Matagorda County The Annex and the' Tab will be revised to be consistent.
Procedure 4 has been superceded.
G.4.b.
Plan. Se ct ~. V.B.14.d (24),
Conflicts in the plan and Annex, over'
-ADEQUATE Annex W. Sect. V.D.7 responsibility for EIP result in con-JPrevious )
-(W-23) fusion ovee coordination of information
, (Inadeq ua te) at the local level.
-(Rasolved )
We recommend that the PIO be designated as-responsible for EIP and as the j
principle spokesperson for the.' locality..
Action taken by Matagorda County Procedure 4 'has 'been superseded by 'the Manual of Emergency Procedures, Section-VII, with responsibility assigned to the Public Information Officer. Emer-3 gency Public Information is the.respon-sibility; of the Emergency Director and he will designate a Public Information Office. Annex W,Section V.D (page. 20-
- 21) has been revised to indicate that a Public Information Officer is designated.
' The Public' Information Officer will. be l
,.')'
16.
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES G.4.b (cont'd) normally assigned to serve at the Media Center as an interface with the County EOC.
Chief s of Police do not have a specific role in EPI.
l G.4.c Plan Sect. V.B.14.c (24),
Plan does not sufficiently address ADEQUATE Annex W Sect. V.D.8 (W-coordinated arrangements for dealing (Previous )
23), Tab 5 Sec. III.C.
with rumors.
(Inadequate)
(W-5-5)
(R; solved
)
Action taken by Matagorda County Rumor control is addressed in the STPECS Emergency Plan. Rumors will be forwarded to the Media Information Center for disposition. Annex W,Section V.D.8 (W-22) has been revised.
)
G.5 Plan Sect. V.B.14.a (23),
Plan calls for the PIO to establish ADEQUATE Annex W Sect. V.D.4 (W-22) and conduct an annual training pro-gram for the media.
H.3 Plan Sect. IV.B (7/8),
County EOC (Sheriff's of fice) and ADEQUATE Tab 9 (W-9-1/13) alternate (County Courthouse) are designated and their operations described.
H.4 Plan Sect. IV.C (8),
The Annex, and Tab 9 Sect. C.2/3 ADEQUATE Annex W Section VI (W-indicate that the EOC will be acti-(Previous
)
34/40) vated and staffed to the level ap-(Inadequate) propriate. However, no system or (R; solved. )
operational procedure for timely I
I activation and staffing is des-c ribed.
l Action taken by Matagorda County 1
(
See Manual of Emergency Procedures,
)
Attachment B, " Procedures for the j
Matagorda County Emergency Opera-tions Center".
3
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117,.
1
'i j
j CONSOLIDATED FEMA /RAC I
REVIEW COMMENTS AND
{
NUREG CRITERION ACTIONS TAKEN BY MATAGORDA l
AND COUNTY TO CORRECT
,n
. EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES j
H. 7.-
, Annex W Sect. V.E Field monitoring is deferred to the ADEQUATE (W-24)
StPte along with almost all radio-
]
logical operations.
State provides 1
almost-all equipment (except for a f
few instruments provided to the l
' county by STPEGS).
j Lists of equipment should be con-I sistent between the plan and the
- procedures.
H,10' Annex W Sect. V.E (W-24),
KbsponsibilitydeferredtotheEtatebut I-ADEQUATE Annex W Sect. V.M (W-31),
County RF0 will assist.
State will Annex U Attach. 3, Tab 4 maintain _ state supplied equipment.
STPEGS Sect. IV.B (W-4-5) will maintain equipment they supply.
If the state has supplied equipment to the locality, it should be listed as an ad-dition to Attachment 3.
0-2 R pocket dosimeters entry on Attach.
r 3 should read 0-20 R.
Even though H.10 was evaluated as ade-quate, the following action was taken by Matagorda County.
j Action taken by Matagorda County Annex W, Section 3 has been revised.
H.11 Annex W Sect. V.E. (W-24),
See comments in H.10 above. Addition:21
' ADEQUATE Anrex W Sect. V.M. (W-31), items included in ' emergency kits' (f f (Previous )
Annex W Attach. 3, Tab 4 the locality intends to have them) should (Inadequate):
Sect. IV.S (W-4-5) be listed (see ' evacuation kit' in (R2 solved )
P30 06).
Action taken by Matagorda County The Manual of Emergency Procedures, Attachment G, Tab 2 has been revised.
f-
r
. s y,i ' : o k-18.
l CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN -BY HATAGORDA AND COUNTY TO CORRECT t
EVALUATION
-CROSS REFERENCES PREVIOUS INADEQUACIES j
H.12 Annex W Sect. V.E Deferred to the State. Cross-reference ADEQUATE (W-24).
to the State plan would be appropriate.
'1.7 Annex W Sect. V.E.
Deferred to the State.
Plan provides ADEQUATQ
.(W-24) that county RDO will assist if re-quested and resources are available.
Cross-reference to State plan would j
be appropriate.
I.8 Annex W Sect. V.E Deferred to the State.
Plan'provides 3
' ADEQUATE (W-24) that county RDO will assist State.if l
requested and resources are available.
Cross-reference to State plan would be appropriate.
'J.2 Plan Sect. - V.B.19 (27),
Plan contains no description of the lo-j
. ADEQUATE
' Annex W Sect. V.K (W-'
calities proposed actions to support an
.(Previous )
29/30), Annex W Sect.
evacuation of on-site personnel.
STPEGS i
(Insdequate)
V. A. 7 (W-17 ), Ta b 3 is responsible for the personnel only (Resolved )
Sect. III (W-3-2/15) unti1 ~ they move of f ' the site, then the -
county'becomes responsible for con-i troling their movement and receiving j
and housing them.
Action taken by Matagorda County
]
Local assistance may be needed to support evacuation of onsite personnel.
If private transportation cannot 'be
)
used, school buses may be used for i
evacuation of onsite personnel. Also, i
law enforcement preonnel may be
)
necessary to direct personnel to a
~
h ~ ;o 0...,
'F I f
- 19 *.
I CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND' NUREG CRITERION ACTIONS TAKEN BY MATAGORDA 2AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES-PREVIOUS INADEQUACIES J.2 (cont'd) reassembly area outside of the EPZ.
Annex W,Section V.K.8 will be re-l vised to reflect this change. Annex W.
Section V.I.1 covers ' traf fic control.
In addition, Annex W. Tab 8 will be revised to include a summary of local support activities for an onsite evacuation.
J.9 Plan Sect. V. A.1.c (10),
Determination of recommended protective ADEQUATE Annex W Sect. V.A.6/7' actions is made by the State based on (Pravious )
(W-17), Annex W Sect.
STPEGS recommendatons and PAG's.
The (Inideq uate)
III (W-4-3/5) locality will disseminate recommenda-(R2 olved )
Procedure 2 p. 12 of tions to the public via the EBS and 56 other' media.
See comment under A.1.b above.
Action taken by Matagorda County See Manual of Emergency Procedures.
Sections I and VII. See response to A.1.b.
HJ.10.a Tab 3 Figures 1 & 2, Maps showing evacuation areas and ADEQUATE' Annex W Sect. V.E (W-routes, with control points, are in-(Pravious )
24) cluded in the plan. Additional maps (Inzdequate) of the support faciities in Bay City (Ra:olved )
and Palacios (now included in Tab 1, Chapter 2 of the State Plan) should also be included in the County plan.
Action taken by Matagorda County Maps of the support facilities in Bay City and Palacios (from Tab 1, Chapter 2 of the State Plan) have been included in the. County Plan.
(Annex W, Tab 3, Figures 4 and 5.)
..O..
4 20.
CONSOLIDATED FEHA/RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES J.10.b Tab 3 Figure 4 The map included in the plan shows ADEQUATE population by sectors, not by evacu-(Previous )
ation areas as required.
(Inadequate)
(Resolved
)
Action taken by Matagorda County Annex W, Tab 3 (addendum to Figure 2) will be revised to include the popu-lation by zones.
~
Estimated Population of Evacuation Areas 1 Area 1 6
Area 2 3
Area 3 139 Area 4 60 Area 5 141 Area 6 55 Area 7 275 Area 8 235 Area 9 159 Area 10 601 i
Area 11 159 Area 122 19 l
Area 132 127 Area 142 486 Area 152 1500 Area 162 1500 Note 1:
These values were derived from the population distributed over sectors in the five and ten-mile rings.
Note 2: Areas 12,15 and 16 extend outside the 10-m11e EPZ. The popula-tion of areas 15 and 16 are primarily outside the 10-mile EPZ.
l
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CONSOLIDATED FEMA /RAC REVIEW COMNENTS AND NUREG CRITERION ACTIONS TAREN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES, PREVIOUS INADEQUACIES J.10.c Tab 1 Sect. III (W Systems and equipment for notification ADEQUATE 2/7) of the resident population are described (Previous )
and the decision process and notifica-(Inadeq ua te) tion flow are illustrated.
Notification (Rssolved )
systems for the transient population should be included.
j Action taken by Matagorda County See Manual of Emergency Procedur'es, Attachment F, " Standing Operating Procedure for Public Warning of a Fixed Nuclear Facility Incident".
Tab 1 has been revised.
If conditions allow, vehicles will be l
used for route alerting in their assigned area, broadcasting emergency information, until (1) evacuation is
{
complete, if evacuation is recommended, (2) all residents have taken shelter, if shelter'is being recommended, or (3) until recalled or reassigned.
J.10.d Annex W Sect. V.D.12 Plan assigns responsibility to County ADEQUATE (W-24), Tab 8 Sect. III Coordinator for identifying persons (Previous )
(W-8-2/6), Tab 3 Sect.
requiring special assistance. However, (Inadequate)
IV.B.2.h (W-3-6) it does not describe the means for pro-(Resolved )
tecting these persons. The list of special f acilities (p. W-8-2) appears to be incomplete.
No hospitals, jails, nursing homes, etc. are included.
)
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/22.,
I CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND' NUREG CRITERION.
ACTIONS TAKEN BY MATAGORDA j
AND.
COUNTY TO CORRECT '
l EVALUATION-CROSS REFERENCES-
~ PREVIOUS INADEQUACIES 1
i J.10.d (cont'd)..
Action Taken by Matagorda County
.4 Transportation for.those needing special,
j assistance will be provided throughithe.
Transportation Officer..See Annex W.
Section V.K.4.(W-29).
There are no.
1 hospitals,. jails, or nursing homes within the 10-mile-EPZ.
J.10.e
. Annex W' Sect. V.M.2.
Plan defers all considerations-of radio-
. ADEQUATE' (W-31)
. protection drugs to the State.
Ji10.f.
Annex.W Sect. V.M.2 Same as J.10.e above.:
ADEQUATE ~
-(W-31).
fJ.10.g.
Annex W Sect. V.K.(W-29/.
Concept - of ' relocation operations indi-
~
' ADEQUATE
.30), Tab 8 Sect. III (W-cates school. buses, private cars and.
j
-(Pravious ):
=8-2/6) sheriff's vehicles will be used..-
j
~(Insdequate)
.(Rasolved--)
Amplification of the'~ "special, arrange-ments" for. persons'who cannot'get to the area assembly'pointsimust be in-i cluded'to satisfy the requirements
'of this element.
Action taken by Matagorda County Assistance will be provided'to identi-fled persons requiring transportation assistance. A list of those needing -
assistance will be maintained. Annex W,Section V.K.4 and Tab 8, Section.
III.B.2 have been revised.
i i
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2.1 is, E 3.;'
2
\\
CONSOLIDATED FEMA /RAC
]
REVIEW COMMENTS AND.
NUR'EG CRITERION ACTIONS TAKEN BY MATAGORDA i.
AND COUNTY TO CORRECT EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES J.10.h Tab 7 Attach.1 & 2 The County has established a11' recep-tion centers and shelters within its own area and under its own control.
Therefore, they are NOT five or more miles outside the boundary of the plume EPZ.
Placing the centers and shelters farther out would put them in other counties creating coordina-tion and jurisdiction problems.
This entire issue was thoroughly dis-cussed and reviewed with FEMA National.-
An exemption was granted by FEMA,since the next closest Reception Center Site would be 23 miles outside the 10-mile plume EPZ. Thus, an adequate evalua-tion was determined.
i
.J.10.1 Tab 3 Sect. III.F (W-Plan indicates worst-case movement
' ADEQUATE 3-14)-
studies show entire EPZ can be evacu-l (Previous )
ated in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. However, projected (Inadeq uate) traffic capacities of evacuation
'(R2 solved )
routes are not included in the plan.
Action taken by Matagorda County' 1
i A study of the-local roadway network definition and capacities is available
-]
as part of " Evacuation Time Estimates for the South Texas Project Electric Generating Station Plume Exposure Pathway Emergency Planning Zone", by HMM Associates.
1 I
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24.
CONSOLIDATED FEMA /RAC l
REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION _,
CROSS REFERENCES PREVIOUS INADEQUACIES J.10.j Plan Sect. V.B.l.d 13, Sheriff assigned responsibility for ADEQUATE Annex W Sect. V.I.2 control of evacuated areas. Procedure (W-27) 06 describes methods of control.
(procedures 06 (8) & (16/
- 17) should be added Suggest that Procedure 6 include identification of support by BRC personnel assigned to control points.
J.10.k Tab 3 Sect. III.C.6 (W-Plan does not identify means for deal-ADEQUATE 3-14) ing with impediments.
It assigns re-(Previous )
sponsibility to the sheriff to review (Inadequa te) the routes, with the State, to insure (Rssolvee )
passability under all conditions..
Action taken by Matagorda County Action can be taken by the Sheriff as appropriate for the circumstances.
This is reflected in a revision to Tab 3,Section III.C.6 (W-3-9).
J.10.1 Tab 3 Sect. III.F (W Evacuation time studies have been ADEQUATE 14) separately supplied for review.
J.12 Tab 3 Sect. III.D (W Plan indicates that evacuees will be ADEQUATE 10/11) registered and monitored but doesn't (Previous )
(Procedure 09 should be say how. Pro 09 provides general (Inadequate) added guidance to ARC & ISD's but no spe-(Rasolved )
cific steps to follow. No mention of the 12-hour requirement for moni-toring of evacuees is made.
Action taken by Matagorda County See Manual of Emergency Procedures.
Attachment H, and revised Tab 3,Section III.D.4 (W-3-10).
l
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3 i
k D
2 5,.
-)
f 4
CONSOLIDATED FEMA /RAC
]
-REVIEW COMMENTS AND-I
- NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFEREFCES PREVIOUS INADEQUACIES 1
l J.12 ' (cont 'd ) '
There will be a sufficient amount of equipment and personnel to enable monitoring within a 12-hour period of all residents and transients evacuated from the plume exposure EPZ.
K.3.a Annex W Sect. V.M-(4-31),
ADEQUATE (Procedure 7, Addendum 6 '_
Paragraphs.M2 and M3 of the Annex and Paragraph 4.0 of the procedures are in (Previous )
should be added) conflict on dosimetry issue.
The plan
'(Inadequate).
does not provide fcr reading or record-
.(Easolved- )
ing of radiation exposures except by l
State BRC personnel. These issues must be clarified.
Action taken by Matagorda County ~
Exposure control for emergency personnel shall be conducted in accordance with State guidelines. County personnel will provide radiological monitoring assist-ance and dosimetry issue and control.'
The Manual of Emergency Procedures,-'Sec-tion V, covers use of dosimetry by local response personnel. Annex W, j
Section V.M.2 (W-31) has been revised.
1 K.3.b Annex W Sect. V.M (W-31).
See K.3.a above.
' ADEQUATE (Previous )
Action taken by Matagorda County (Inadequate)
(Rasolved -)
Dosimeters will be read at frequencies 1
to be specified by state guidelines.
Dose records of. emergency workers will be maintained in accordance with State guidelines. Manual of Emergency Pro-cedures,Section V and Annex W, Sec-tion V.M.3 (W-31) have been revised.
i i
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,y
,p-I CONSOLIDATED FEMA /RAC' j
REVIEW COMMENTS AND j
- NUREG CRITERION l ACTIONS TAKEN BY MATAGORDA' AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES l
'K.4.
Annex W Sect. V.A.9 Plan. designates County Judge and Mayors ADEQUATE (W-18) as responsible for decisions about radio-logical exposures-in excess of EPA or other guidance.
{
i K.5.a-Annex W Tab 3 Sect.
Neither cross reference addresses'the
- ADEQUATE III.d.4 (W-3-10/11),
requirements of this element.
Deter-(Previous. )
Annex'W Sect. V.M.1 mination of Action Levels may be de-(Inadequate);
(W-31) ferred to the State but this does not
]
-(Rasolved )
absolve the locality.of responsibilty for determining their own requirements.
I Action taken by Matagorda County-c; As a minimum, decontamination will be performed in accordance with State regulations on acceptable. levels of contamination. Annex W,-Tab 3, Sec-tion III.D.4 (W-3-10) will be revised.
j l
The Manual of Emergency Procedures j
covers decontamination in Attachment K..
-K.5.b Annex W Sect. V.J.4 While assigning responsibility for de-
~
. ADEQUATE
'(W-28), Annex W Sect.
contamination guidance to the County (Previous )
.V.M.-(W-31/32)
RDO, the plan does not establish means
.. Inadequate) for decontamination or for waste dis-(
- (Rasolved. ' )
posal.' County plan cross reference j
indicates ' deferred to the State' 4
while the State plan says that decon
'is a' local retconsibility. There is
'l no requirement for disposal of 'de-l contaminated' waste (see p. W-28).
A
- 1.. A L,. -
f.
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.22.
CONSOLIDATED FEMA /RAC I
REVIEW COMMENTS AND i
NUREG CRITERION.
ACTIONS TAKEN BY MATAGORDA
{
AND COUNTY TO CORRECT 1
EVALUATION CROSS REFERENCE 3 PREVIOUS INADEQUACIES i
J K.5.b (cont'd)
Action taken by Matagorda County i
Annex W,Section V.J.4 (W-28) states that disposal of decontamination waste
/
will be handled by the STPEGS, result-ing from injured patients with radio-logical contamination relative to medical services. The same is true for other decontamination waste.
All contaminated waste will be t'urned over to STPEGS. Annex W,Section V.M.8 (W-31) has been added to reflect this change.
L.1 Plan Sect. V.B.9.1 (20)
Plan assigns responsibility to the
-ADEQUATE Annex W Sect. V.J.
Matagorda Co. Hospital District (Previous )
(W-28)
Administrator 'and describes the
' (Inadequa te) things that should be done. How-
-(R3 solved )
ever, it contains.no indications H
that persons providing required services are adequately prepared.
Action taken by Matagorda County See Annex W, Tab 6,Section III.C.
(W-6-3).
A training program has been initiated which shall provide for instruction and qualifications, where appropriate, i
for personnel who provide the radio-logical response ef fort. The program includes periodic retraining, including i
I
1.. q ;.. -.
k'
-28.
CONSOLIDATED FEMA /RAC.
REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA' AND COUNTY TO CORRECT EVALUATION' CROSS REFERENCES PREVIOUS INADEQUACIES L.1-(cont'd) the scope, nature, and f requency, for medical support personnel.
In addition, a medical emergency drill which contains provisions ~for participation byfthe STPEGS, hospitals, an. ambulance service, involving a simulated ' contaminated in-dividual shall be conducted annually.
' L.4' Annex W Sect. V.J.9 Like L.1 above, the plan shows what
-ADEQUATE (W-29) should be done but contains no indi -
L(Previous
),
. cations that arrangements have been.
' (Inadequa te) made or personnel adequately prepared.
(Rssolved )
See response ' to L.1.
In addition, Taylor: Brothers Funeral Home is under contract to provide-county-wide ambulance service, and participate in the program. described.
-in response to.L.1.
Mel Plan. Sect. VI.E (32/33),
Plan assigns responsibility to County ADEQUATE Annex.W Sect. VI.e (W-Judge, and lists actions that may be-(Previous. )
39/40) necessary. However, it does. not ' des-7 (Inadequate) cribe how these actions are to be ac-t (Rasolved) complished.
Action taken by Matagorda County Re-entry and recovery will be performed in accordance with guidance by the State. Annex W, Tab 3,Section III.G.4 (W-3-16) has been revised.
)
.i;. 4,...
2:
2 9., ' '
16 i
I CONSOLIDATED FEMA /RAC.
REVIEW COMMENTS AND
-NUREG CRITERION ACTIONS TAKEN BY MATAGORDA
-AND' COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES
.j N.1. a --
Plan Sect. - V.A.2.g (12),
Plan requires county personnel parti-
~ ADEQUATE Tab 6 Sect.'III.E (W-6-6) cipation in exercises as outlined in FEMA and NRC rules.
i N.l.b
' Tab 6 Sect. III.E/F/G Plan makes no mention of varying scen-ADEQUATE (W-6-6/8) arios, the six-year exercise cycle, (Previous )
after-hours. tests, or other variable (Inadequate) factors.
(Rasolved )
Action taken by Matagorda County e
Annex W, Tab 6,Section III.E (W 6) has been revised as follows:
Full participation exercises will be conducted at. least every two years to demonstrate the effectiveness of -
the County emergency preparedness effort. The exercises will include.
mobilization of State and local per-sonnel and resources.to verify their capability to respond to an accident -
situation.
Involvement by the support organizations will belas appropriate to -
' the exercise objectives.
An exercise will be started between 6:00 p.m. and 4:00 a.m. once ewery six years.
Exercises will be conducted under various weather conditions.
Some exercises will be unannounced.
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t
)
I I
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3 0.
- CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT I
EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES f
I l
N.l.b (cont'd)
Scenarios governing the exercise will be varied, such that all major elements of the plans and preparedness organiza-j tions are tested within a six-year period.
Confidentiality will be i
maintained on the topic of each I
scenario.
N. 2. a -
Tab 6 Sect. III.D.l.a/c The plan adequately addresses the re-
)
ADEQUATE (W-6-4/6) quirements of communications drills.
I N. 2. c.
Tab 6 Sect. III.D.1.d The plan adequately addresses the re-ADEQUATE (W-6-5) quirements of medical emergency ' drills.
N.2.d Tab 6 Sect. III.D.l.e The plan adequately addresses the re-ADEQUATE (W-6-5)
' quirements of radiation monitoring drills.
j 1
N.3.a thru f Tab 6 Sect. III.F The plan adequately addresses each of 1
ADEQUATE (W-6-7) the separate elements under N.3 relat-(
ing to exercise objectives.
N.4 Tab 6 Sect. III.G The plan adequately addresses the op-ADEQUATE (W-6-8) erations of of ficial observers and the 1
critique.
f N.5 Tab 6 Sect. III.G The plan adequately addresses evaluation j
ADEQUATE (W-6-8) of exercise comments and implementation
(
of corrective actions.
0.1 Plan Sect. V.A.2.g (12),
Plan adequately addresses requirement ADEQUATE Annex W Sect. IV.A.5 for participation in training for all (W-13) off-site personnel.
0.1.b Plan Sect. V.A.2.g (12),
Plan adequately addresses requirement ADEQUATE Tab 6 Section III.c (W-for participation in training for all 6-3/4) of f-site organizations.
t'
..O,a.'
s-4 j
31.
I i
CONSOLIDATED FEMA /RAC REVIEW COMMENTS AND NUREG CRITERION ACTIONS TAKEN BY MATAGORDA AND COUNTY TO CORRECT EVALUATION CROSS REFERENCES PREVIOUS INADEQUACIES 0.4.a thru j Tab 6 Sect. III.C.3 The plan adequately addresses each of ADEQUATE (W-6-3/4) the elements under 0.4 regarding per-sonnel to participate in specialized training programs.
0.5 Tab 6 Sect. III.A (W-The plan adequately provides for per-ADEQUATE 6-2) iodic retraining on an annual basis.
1 P.1 Annex W Sect. V.A.8 Plan identifies the County Judge ~and
)
ADEQUATE (W+18)
Mayors as responsible for the planning j
(Plan Sect. V.A.l.b effort, designation of a planning co-should be added) ordinator and training of those respon-sible for planning.
P.2 Plan Sect. V.A.1 (10)
See P.1 above.
ADEQUATE P.3 Plan Sect. V.A.2 (11/12)
See P.1 above.
ADEQUATE
-P.4 Plan Sect. X (35)
NUREO 0654 calls for an annual recerti-ADEQUATE fication of the plan, not biennially as (Previous )
the plan states.
(Inadequate)
(Rssolved )
Action taken by Matagorda County i
This item has been corrected, see Plan Section X (36).
g P.5 Plan Sect. V.A.2.e (12)
Plan does not require revised pages to ADEQUATE be dated and marked to show where q
(Previous )
changes are made.
j (Inadequate)
(Resolved
)
Action taken by Matadorda County Section V.A.2.e has been revised to require pages to be dated and marked.
j i
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-w?
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3 7. -:
1 f
1
' CONSOLIDATED FEHA/RAC REVIEW COMMENTS AND NUREG CRITERION '
ACTIONS TAKEN.BY MATAGORDA JAND COUNTY TO CORRECT
' EVALUATION -
CROSS' REFERENCES PREVIOUS INADEQUACIES L
-P.6 Plan Sect. I (1)
Plan indicates'the Texas State. Plan is
- ADEQUATE, the supporting plan.
Is this the only supporting Plan?
P.7 Tab 10 (W-10-1)
List of procedures at Tab 10 does not ADEQUATE indicate section(s) of plan implemented
.(Previous
)-
nor do procedures.1 - 11 indicate sec-(Inadequa te) tion of plan implemented.
(Rssolved )
Action taken by Matagorda County
~
Procedures 1-11 have been superseded.
An index of procedures given in the Manual of Emergency Procedures.has been provided in revised Tab 10, which reflects those sections of the plon being implemented.
.P.8 Plan Table of Contents Procedures.have no cross reference and ADEQUATE (ii), Tab 1 (W-11-1/12) there are. numerous typographical and (Previous
).
other errors in the plan cross refer-(Inadequa te) ence. These errors should be corrected c(Rasolved )
and a revised list submitted.
i Action taken by Matagorda County Tab 11 has been revised.
- P.10 -
Tab 1 Sect. IV.F Plan calls for quarterly updating of ADEQUATE (W-1-12) call lists. Also see comment under E.2 above.
I